News & Analysis as of

Retirement Plan Missing Plan Participants Employee Benefits

Husch Blackwell LLP

IRS Issues Guidance on Uncashed Retirement Plan Checks

Husch Blackwell LLP on

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

Bricker Graydon LLP

The DOL Lost and Found Database is Live

Bricker Graydon LLP on

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

Faegre Drinker Biddle & Reath LLP

Things I Worry About (8): DOL Investigations and Unsuspecting Plan Sponsors (2)

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

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Create a missing participant process

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

Faegre Drinker Biddle & Reath LLP

Forced Rollovers of Small Retirement Account Balances: What to Do with Missing Participants

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

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Put a process in place to find missing participants

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

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Missing Plan Participants

Williams Mullen on

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Dealing With Missing Participants in Terminating Puerto Rico 401(k) Plans

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

Bradley Arant Boult Cummings LLP

Missing Retirement Plan Participants? The DOL Says You Should Follow These Best Practices

In response to ongoing pleas for guidance, the Department of Labor (DOL) has published an informal outline expressing its views on how retirement plan administrators should be addressing missing or unresponsive participants....more

Morgan Lewis

DOL Guidance on Missing Participants Is No Longer Missing

Morgan Lewis on

The US Department of Labor (DOL) provided three long-awaited pieces of sub-regulatory guidance on January 12 on the issues of missing participants and uncashed checks. This is an area that has been the subject of a focused...more

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