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- The Missing Participant Problem
- What is a Missing Participant?
- Why Plan Sponsors Should be Concerned
- What Causes Missing Participants?
- The Magnitude of the Problem
- What Regulations Apply to Missing Participants?
- Sources of Uncertainty for Plan Sponsors
- Best Practices for Finding Missing Participants
- What to Look For in a Search Service
- Learn More About Missing Participants
- RCH's Missing Participant Search Service
- Terminating 401(k) Plans
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Sources of Uncertainty for Plan Sponsors
- Lack of Guidance: Most recent guidance from the Department of Labor – DOL Field Assistance Bulletin 2014-01 – addressed terminated plans only, and does not address ongoing plans.
- Inconsistent Enforcement Positions: Plan sponsors claim to receive inconsistent enforcement actions during audits, including extreme requirements to “keep searching every year, indefinitely” and to “do whatever it takes” including contacting former co-workers and family, or to notify participants of audit actions.
- Fiduciary Risk: Failure to locate missing participants can result in increased penalties, risk of plan audits and potentially – a breach of fiduciary duty.
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