Missing Participants

WHAT DO I DO ABOUT MISSING PARTICIPANTS?

You need to know how to contact your plan participants! The Plan Sponsor has a fiduciary duty to deliver information (like plan notices, distribution forms, etc.) to their plan participants and if you can’t find your participants then you can’t get information in their hands.

When you have a missing participant, you need to take steps to locate them & DOCUMENT YOUR FILE WITH THE ACTIONS TAKEN TO LOCATE THE MISSING PARTICIPANTS.

The Department of Labor (DOL) has issued guidance documenting steps that must be taken to locate a missing participant for a terminating defined contribution. The DOL has also been investigating plans to assure that plan sponsors are taking steps to locate missing participants.

 

We recommend that these steps be followed whenever you have a missing participant:

1

Review your files for any participant contact info. You may have additional contact information including home or cell phone, alternative home address, e-mail address, etc. in your personnel files, insurance files, medical files, etc. Use all this contact information to contact the missing participant.

2

In your files you may also find contact information for people that may know how to contact the participant. This includes emergency contact information, designated beneficiaries, references on a resume/job application, and designated beneficiaries for retirement plans or life insurance. Use all this contact information to contact the missing participant.

3

Ask current employees that may have contact with the participant if they know how to contact them.

4

Search free computer databases. This should include not only a general search under Google, but also social media such as Facebook and LinkedIn. It may also include public record databases such as state licensing agencies, tax websites, obituaries, etc. Use all this contact information to contact the missing participant.

5

Additional search methods may also be required depending on the circumstances. For example, it may be prudent to pay a locator service like www.employeelocator.com to conduct a missing participant search for you if the participant has a large account balance. Generally, the fees are quite reasonable to conduct a missing participant search.

6

Set a schedule (for example, annually or biannually) to conduct additional searches for all missing participants.

Be sure to document your file with all actions taken to locate the missing participant.

HOW DO I AVOID HAVING MISSING PARTICIPANTS?

Some of the steps that you can take to avoid having missing participants include:

  1. Conduct an exit interview and verify current contact information
  2. Give the participant a memo describing the distribution process so they can easily receive their distribution at the appropriate time
  3. Remind the participant to keep their contact information up to date with the recordkeeper