Annual Benefits Forum: How To Be an ERISA Superhero
PODCAST: Williams Mullen's Benefits Companion - Missing Plan Participants
The IRS has released Revenue Ruling 2025-15, which clarifies the federal tax withholding and reporting responsibilities of retirement plan administrators when a distribution check is issued but remains uncashed and a...more
Late last year, the Department of Labor (DOL) launched the public Retirement Savings Lost and Found Database. Created as part of SECURE 2.0, the DOL hopes that the database will serve as a centralized location to help missing...more
The February Monthly Minute highlights a new online ACA reporting alternative, the DOL’s temporary policy regarding escheatment of small retirement benefits owed to missing participants, and new guidance clarifying the gag...more
As explained in my last post, Things I Worry About (7), the DOL’s EBSA has a number of programs that can restore benefits to plans and participants. Those include: - Civil investigations. - Criminal investigations. -...more
The March Monthly Minute digs into an Ohio district court ruling that rejected application of a medical plan exclusion, missing participant guidance and related audit concerns, and responses to the Change Healthcare...more
There is a reason I stopped working for people, so I understand the Great Resignation and people’s disgust with working with others, and that was way before COVID....more
In January of 2021, we published two blog posts regarding Department of Labor (“DOL”) guidance on missing retirement plan participants. The first post describes DOL guidance on best practices for locating missing retirement...more
About 75% of large 401(k) plan sponsors would rather keep the assets of retired employees in the plan, rather than have these retirees roll over their plan assets into an individual retirement account (IRA), according to a...more
It’s more work, but it’s clear that the Department of Labor (DOL) wants you to do more work when dealing with former participants who you lose track of, but still have money in your 401(k) plan....more
Williams Mullen Employee Benefits team share their superpowers and help you fight villains like noncompliance, penalties, and operational errors including; guarding against ineligible dependents with self-audit tips, decoding...more
When a participant experiences a distribution event (e.g., terminating service with the employer), and when the participant does not affirmatively elect to take the distribution, a plan document may require that an account...more
More than 16 million accounts of $5,000 or less — $8.5 billion in the aggregate — were left in workplace plans from 2004 through 2013. That is part of the reason that the DOL believes that dealing with the missing participant...more
The focus of the US Department of Labor (DOL) on missing participants and uncashed checks (discussed in our LawFlash DOL Guidance on Missing Participants Is No Longer Missing) recently began expanding into the area of...more
Let the Williams Mullen Employee Benefits team share their superpowers and help you fight villains like noncompliance, penalties, and operational errors! You’ll be ready to: - Guard against ineligible dependents with our...more
On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt is joined once again by Beryl Ball, Principal Financial Advisor at CAPTRUST, who explains the Department of Labor’s recent guidance for plan sponsors...more
Bad Behavior You Shouldn’t Replicate As A Plan Provider. I like to treat people the way I wanted to be treated. It usually works out, but there are instances where the other side doesn’t follow the path I’ve taken. As a...more
According to the Department of Labor, you have a missing participant problem if: 1) You have more than a small number of missing or nonresponsive participants. 2) You have more than a small number of terminated vested...more
With the focus by the Department of Labor (DOL) on missing participants, I have to say it isn’t hard to find missing participants. While you could rely on the automatic rollover provider, the Internet has made searches easy...more
By now, you’ve probably read about the Department of Labor's new guidance on locating missing retirement plan participants. And, as you’re probably already aware, missing participants (and beneficiaries) can be a real...more
On January 12, 2021, the Department of Labor (“DOL”) issued guidance that is intended to help retirement plan fiduciaries meet their ERISA obligations to locate and distribute benefits to missing or nonresponsive...more
The problem of “missing” participants and beneficiaries (individuals for whom the plan administrator does not have adequate contact information) is an ongoing issue for retirement plan administrators. It is also an area to...more
The DOL recently issued Field Assistance Bulletin 2021-01, blessing the PBGC’s Missing Participant Program as an additional method of addressing a perennial issue in 401(k) terminations – the problem of missing participants...more
On January 18, we published a blog post regarding new Department of Labor (“DOL”) guidance on missing plan participants. That post is available here, and describes the DOL’s guidance on Missing Participants - Best Practices...more
For a host of legal and practical reasons, the only feasible alternative for disposing of the accounts of missing participants in a terminating 401(k) or other defined contribution retirement plan qualified only in Puerto...more
The Department of Labor (“DOL”) has undertaken a nationwide compliance initiative to ensure that retirement plan participants receive the benefits that they were promised when they reach their retirement age. To that end, the...more