Locating missing plan participants

As a plan fiduciary, you have a responsibility to maintain accurate participant information and to take steps to help ensure retirement benefits and required documents are successfully provided to your plan’s participants. Failure to take appropriate steps to locate missing participants can result in penalties, risk of plan audits and, potentially, a breach of fiduciary duty.

Best practices for managing missing participants

In January 2021, the Department of Labor issued guidance in the form of best practices for maintaining participant information and locating missing participants and beneficiaries. We’ve summarized some of these best practices below to help you fulfill your fiduciary obligations.

Keep in mind, not every practice is appropriate for every plan. You should consider the size of a participant’s account balance as well as the cost of any search efforts when determining which steps may be appropriate.

Maintain accurate participant information

  • Contact participants, both active and retired, on a regular basis to confirm or update their contact information (including beneficiary and emergency contact information, if applicable).
  • Audit the participant information periodically and correct any errors.

Conduct thorough participant searches

  • Attempt to contact the participant via all phone numbers and email addresses that you have on file.
  • Use free online search tools, public records databases and social media to look for additional contact information.
  • Check with the participant’s designated beneficiaries and emergency contacts; if they have privacy concerns, you can ask them to forward a letter to the participant.

Document your procedures and actions

  • Develop clear procedures and put them in writing to help ensure consistent practices.
  • Document the decisions and actions that you’ve taken to implement procedures and efforts to locate missing participants.

Identifying and preventing missing participants

We send participant statements and other plan information to participants on your behalf. Depending on the services you have elected, and information provided, other plan information may include regulatory notices and enrollment materials. Be sure to provide us with complete and up-to-date participant data. When participant data is incorrect, we receive returned mail and are unable to mail information to participants.

As a reminder, to help you identify participants with incorrect addresses, we make a report available for you to run on the Plan Service Center website that identifies participants with incorrect addresses. The sooner you identify incorrect data, the easier it’s likely to be to locate the participant’s correct contact information.

Need help?

Contact your third-party administrator or service representative for additional guidance.

You can also call us at (877) 872-5159 for assistance with undeliverable mail and missing participant accounts.

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