One of the hottest topics among plan sponsors these days seems to be the issue of missing participants – more specifically, how far do you need to go? This week, we’d like to know what you’re hearing – and doing.
The IRS, Labor Department and PBGC have been closely monitoring how employers are dealing with missing participants and increasing their enforcement activity, and the DOL’s Field Assistance Bulletin (FAB) 2014-01, which is the agency’s primary guidance on procedures for dealing with missing participants, only addresses terminating DC plans, leaving sponsors unsure of whether the guidance applies to ongoing plans. Similarly, the PBGC recently expanded its missing participants program, but it only applied to terminated 401(k) plans, multiemployer pension plans and small professional service DB plans with 25 or fewer participants. More recently, the Government Accountability Office (GAO) has called on regulators to provide clarity on the issue. And bipartisan legislation has been introduced dealing with the subject.
This week, and with clear and concise guidance arguably still lacking, we’d like to know – is this a concern for your plan sponsor clients, how are they dealing with the issue, and what is your most successful method of assisting plan sponsors in locating missing participants?
Reply to this week’s NAPA Net reader poll at https://www.research.net/r/DRSVR6F.
And, of course, we’ll have it all wrapped up for you on Friday!
