TRANSCRIPT:

Tom Hawkins: Welcome to the 22nd episode of the RCH Consolidation Corner Channel, where we provide audio content that explores key issues in the preservation and consolidation of retirement savings. In this episode, we offer you some helpful tips in dealing with the issue of missing and unresponsive participants in retirement plans. We hope you’ll find the audio enjoyable and informative.

NARRATOR:

Today we’re talking about a topic that frustrates nearly every plan sponsor: missing participants. These are former employees who’ve left your company but haven’t kept their contact information up to date.

Missing participants aren’t just an inconvenience—they’re a fiduciary risk. Regulators expect you to make reasonable efforts to locate them, and failure to do so can lead to compliance headaches. The good news? With the right mix of structure, diligence, and technology, you can dramatically reduce your caseload. Let’s dive into some practical, field-tested tips.

Before you expend company funds on search services, start by combing through your own records. You’d be surprised how often the correct information is already in your system. Check your plan and payroll files for alternate addresses, phone numbers, or emergency contacts. Beneficiary forms and loan applications are gold mines—participants often use more up-to-date addresses there than on their original enrollment forms.

And if your organization has been through mergers, acquisitions, or a change in payroll vendors, don’t forget to examine legacy systems. Lost participants can often be rediscovered by reconciling old HR or payroll data. Sometimes, the answer is hiding in plain sight.

If internal efforts don’t work, it’s time to look outward. Commercial search services can be a great option but use them wisely. Start with low-cost electronic searches. These should scan multiple databases for updated addresses and should also check for indications that a participant might be deceased, along with contact information for close relatives if available.

For participants whose initial searches don’t yield results, selectively increase search intensity. Not every missing participant requires a full-blown forensic search, but high-value or time-sensitive cases may warrant them. Think of it as dialing up the intensity only when necessary.

Finding an address is often only half the battle, particularly for unresponsive participants. Outreach matters—and too many efforts fail because they’re unconvincing or confusing. Effective participant communications should clearly identify who you are. Use your company and plan name, logo, and recognizable branding so participants know the message is legitimate. Create urgency with messages like, “Don’t risk losing access to your retirement benefits.”

And simplify the response. Offer multiple, easy-to-use channels—call center, website, IVR—and make the process crystal clear. When necessary, send mailings to multiple addresses, including those found during your search process. In an era of phishing scams, clarity and credibility are essential.

Every search and outreach activity should be backed by detailed documentation—not just for fiduciary protection but also for audit readiness. Keep an audit-ready record of every step: when and how each search was performed, which databases or services were used, any results or evidence of outreach attempts, and final determinations for each participant. If participants should be receiving benefits but remain missing, having your commercial search provider supply an audit letter attesting to the steps taken can be extremely helpful.

While there are effective ways to find missing participants, prevention is always cheaper and easier than cleanup. Consider embedding these practices in your plan’s day-to-day operations.

  • Deal with small accounts by adopting a fiduciary-friendly automatic rollover program that includes balances below $7,000 and supports auto portability.
  • Capture personal contact details early—before employees leave, collect their personal email and mobile number. Corporate contact info goes stale fast.
  • Encourage online registration. Participants with digital access to their accounts are far less likely to become missing.
  • Send periodic reminders to verify or update contact info, especially before job changes or layoffs.

Each of these steps helps build a foundation of accurate, up-to-date participant data, reducing the risk of accounts going dormant or unclaimed. Doing these things consistently will reduce your missing participant caseload, manage your risk, and save you from chasing ghosts. Instead, you’ll spend more time helping participants achieve better retirement outcomes.

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