Missing Participants – Employee Benefits

A missing participant is a participant or beneficiary who is a former employee for whom the plan administrator does not have current or adequate information. Common signs of a missing participant include returned mail and/or email, no web account or phone activity, outstanding/uncashed distribution checks.

In January of 2021, the Employee Benefits Security Administration (EBSA) issued two new guidelines including best practices and explaining EBSA’s processes regarding participants. The Department of Legislation (DOL) issued Field Assistance Bulletin 2021 – 01 on how to use the PBGC (Pension Benefit Guarantee Corporation)  Missing Participant Program to terminate contribution plans (Please refer to this Bulletin).

Best practices for a plan administrator requires maintaining accurate participant census data as follows:

• Contact participants and beneficiaries on a periodic basis to confirm or update information
• Send reminders about updating information.
• Allow participants and beneficiaries to update information online.
• Work with the plan’s actuary to obtain changes to status and contact information

Missing Participant Searches:

• Check employer records for participant/beneficiary and next of kin information  (e.g,. health plans or other employer benefit plans).
• Use online search engines to locate public records, such as obituaries and social media, mortgage information and credit ratings.
• Send correspondence requesting updated contact information via certified mail.
• Register missing participants on public and private pension registries  (such as the National Registry of Unclaimed Retirement Benefits).
• Contact colleagues of the missing participant.

In First State Trust Company’s (FSTC) capacity as a directed trustee, the plan administrator or actuary directs any changes to participants and beneficiaries. FSTC also provides the pension plan sponsors and/or actuaries with a quarterly death audit. The plan administrator can then research and request changes to living or deceased status.

If the participant status is deceased, the plan’s benefits may be due to one or more beneficiaries, which the plan administrator or actuary must locate the same as a missing participant.

If a plan sponsor has been unable in their attempts to locate a missing participant, they can contact their  trust officer who will work with a FSTC’s compliance officer to conduct a CLEAR/Worldcheck (compliance utilizes Thomson Reuter’s proprietary public records software)  to obtain any changes and confirm with the plan administrator or actuary to direct FSTC to process the changes.

For more information, please feel free to contact me:
Renee Slicer, AVP / Trust Officer
Phone: (302) 573-5804 / rslicer@fs-trust.com

The posts expressed are views of FSTC and are not intended as advice or recommendations. FSTC does not offer tax or legal advice, professional counsel should be sought for tax or legal advice. For informational purposes only.