All large retirement plans will face challenges related to lost or missing participants. These are individual plan balances where the plan sponsor and recordkeeper have lost contact with the individual account holder. These are typically smaller balances, so one way to minimize the issue is to periodically force out plan balances under $5,000. While this may help, it will not make the problem go away completely.
In 2021, the Department of Labor (DOL) issued guidance on the topic (see previous blog post), details of which can be found in Multnomah Group’s Fiduciary Training Program L3 Resource. The guidance does not require plan sponsors or recordkeepers to adopt specific practices. It does provide a variety of steps a plan sponsor can take to keep track of current participants, as well as suggestions to help identify participants once they are lost or missing.
In addition to the DOL guidance, we expect additional legislative and regulatory activity related to this topic. The proposed Securing a Strong Retirement Act (also dubbed SECURE Act 2.0) currently includes a provision to create a national database to track lost or missing participants. Also, in late 2021, the IRS issued guidance on priority areas of focus for 2022. The list included developing guidance on addressing missing participants and uncashed checks.
Plan sponsors should work with their recordkeeper to understand the steps currently in place related to this issue. If there is a problem with lost or missing participants, they may need to take additional steps. For more information on this topic, don't hesitate to get in touch with a Multnomah Group consultant.
You can download our L3 Fiduciary Training resource focused on the DOL's guidance and best practices around lost or missing participants by clicking here.
Multnomah Group is a registered investment adviser, registered with the Securities and Exchange Commission. Any information contained herein or on Multnomah Group’s website is provided for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and, unless otherwise stated, are not guaranteed. Multnomah Group does not provide legal or tax advice.