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Dialing Up the Intensity of Missing Participant Searches
Best Practices for Finding Missing Participants
An emerging framework that could represent the best practices for locating missing participants balances the intensity of the search with the status of the missing participant.
For example, consider the following three scenarios:
1. Participant is well in advance of a normal distribution event.In this circumstance, a participant may not be receiving normal plan mailings.
Search approach: A low-cost, automated search performed yearly
2. Participant is nearing a distribution event. Since the participant is potentially at-risk of not receiving benefits earned, the intensity of the search is increased.
Search approach: An automated search, along with follow-on outreach to the participant and verification of their address (ex. – mailings).
3. Participant is at, or past a distribution event. In this case, the intensity of the search is further increased to include other search tools.
Search approach: Perform a “forensic” search, utilizing a search specialist with additional search tools.
Importantly, in January 2021, the U.S. Department of Labor published a list of their best practices in Missing Participants – Best Practices for Pension Plans.
Finally, locating participants in a terminating plan requires additional DOL-mandated steps, including the use of USPS Certified Mail when initial notification mailings are returned undeliverable.
NEXT TOPIC: What to Look for in Missing Participant Search Services
Dialing Up the Intensity of Missing Participant Searches
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