401k missing participants blog posts


Six Steps to a Strong Missing Participant Policy

Having a documented missing participant policy is about fulfilling a plan sponsor’s fiduciary duty to act in the best interests of plan participants, and to ensure that they receive benefits they are owed. It not only guides a plan sponsor’s actions, but it can also signal to regulatory agencies that a sponsor is serious about undertaking reasonable efforts to identify and locate missing participants. Writing in the Consolidation Corner blog, RCH’s Tom Hawkins provides readers with six steps that are useful for building a strong missing participant policy, and in establishing the framework that guides efforts to locate participants.


A More-Enlightened Approach to Uncashed Distribution Checks

No retirement plan sponsor likes the idea of dealing with uncashed distribution checks, nor do they wish to draw unwanted regulatory attention or to become embroiled in costly litigation. Unfortunately, many plan sponsors place themselves in precisely that spot, becoming unnecessarily over-burdened with unresolved uncashed checks, while inviting unwanted regulatory scrutiny and/or legal challenges by having flawed uncashed check policies. In his 2/8/24 article in RCH's Consolidation Corner blog, Tom Hawkins lays out a "more-enlightened" approach to the problem of uncashed distribution checks, seeking to minimize their numbers, while simultaneously steering clear of the “red flags” that could land them in hot water.


No One is Coming to Save You from Missing Participants

Writing in RCH's Consolidation Corner blog, Tom Hawkins provides his views on the dilemma facing plan sponsors who must confront the problem of locating missing plan participants. Despite ongoing efforts petitioning regulatory authorities for clear, bright line guidance, plan sponsors "must take decisive action to avoid being overwhelmed, including implementing effective, common-sense search practices, and pairing those search practices with other actions that will minimize the incidence of missing participants over time." Hawkins also urges plan sponsors to consider embracing retirement savings portability, including auto portability, to assist separated participants in consolidating their retirement savings following a job change.


Five Tips for Documenting Missing Participant Searches

If a tree falls in the forest, does it make a sound? Opinions are split on this weighty philosophical matter, but a more-definitive answer to another question may surprise you. If a search for a missing participant is not properly documented, is it a diligent search? To regulatory authorities who may scrutinize a plan sponsor’s search efforts, the answer is decidedly “no.” For a regulator to consider a search to be diligent, it must be well-documented, and to do otherwise can result in audits, penalties and increased fiduciary risk. In his latest piece in RCH's Consolidation Corner blog, Tom Hawkins offers readers five tips that will help them better-document their missing participant searches.


As Time Passes, The Gains Become Harder

RCH's Tom Hawkins, writing in the Consolidation Corner blog, observes that our nearly 45 year-old defined contribution system may face diminishing returns as it tries to generate future growth, and should focus on quality and efficiency as it simultaneously expands access. Using fitness as an analogy, Hawkins offers a "workout plan" for the DC system, including plugging leakage through increased portability and emergency savings, while fostering increased retirement savings consolidation to avoid an explosion in small accounts. When combined with expanded access initiatives, these measures can dramatically increase Americans' retirement security, over and above expanding access alone.


The Important Task of Determining Participants’ Life Status

Determining retirement plan participants’ life status is an important, albeit uncomfortable task for plan sponsors. The cost of not knowing participants’ life status, or worse, in getting it wrong – can be significant – for the participants, for their beneficiaries and for the plan itself. RCH's Tom Hawkins, writing in the RCH Consolidation Corner blog, examines the challenges facing plan sponsors in determining life status and identifies three proactive strategies for timely and accurate monitoring of changes.


Dialing Up the Intensity of Missing Participant Searches

Writing in RCH’s Consolidation Corner blog, Tom Hawkins helps plan sponsors understand how and when they should increase the intensity of their missing participant searches. When it comes to locating missing retirement plan participants, Hawkins notes that “there’s no substitute for an effective electronic, or ‘e-search.’ However, retirement plan sponsors will inevitably encounter scenarios where periodic e-searches alone will not suffice.” Hawkins provides plan sponsors with six actionable steps to increase search intensity and offers tips on how to minimize the cost & effort associated with missing participants.


Three Ways 401(k) Plan Sponsors Can Boost Participants’ Awareness on National Financial Awareness Day

Writing in the RCH Consolidation Corner blog, Tom Hawkins draws attention to National Financial Awareness Day, which falls on August 14th. In his piece, Hawkins offers plan sponsors 3 steps they can take to increase financial awareness. Plan sponsors who follow these steps, asserts Hawkins, "won’t simply produce more awareness in the minds of their participants, they’ll generate quantifiable results, coming in the form of decreased cashouts, higher levels of consolidation and average plan balances, as well as a lower incidence of missing participants."