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Hi Bill Thank you for your response. I am agreement with you. Cumulative is the way to go but agent is asking?? Be safe.

Unresponsive participants can only be turned over to PBGC as missing if they are under the cash out threshold or they did not accept their lump sum payment. From MP-100 instructions: Who counts as missing In general, a distributee is considered missing if, when the plan closes out, the plan doesn’t know the individual’s location (e.g., if a notice from the plan is returned as undeliverable). For purposes of these instructions, we use the term “Unlocatable” to describe a distributee in this situation. P 1F P 2 An individual is also considered missing if: • The individual’s benefit was subject to a mandatory cash-out under the plan’s terms and the individual did not return the necessary paperwork providing instructions about how the payment should be made (e.g., by check or as a direct rollover to an IRA); or • The individual did not accept a lump sum payment, whether elected voluntarily or subject to mandatory cash-out (see “Unaccepted lump sum payments” below). We use the term “Unresponsive” to describe a distributee in either of the two situations noted immediately above. Note that a distributee may be both “Unlocatable” and “Unresponsive.” Maybe a letter explaining how the benefit will have to be turned over to an insurance company will get the participants off the snide. This is the biggest pain for small CBPs. Even if the balances were $50k you'd have trouble finding an insurer, and the premiums would likely be 120%-140% or more of the current account balance.

Are they on the enrollment/election forms? If not I'd send a supplemental notices that says something like "While the information on ABC and XYZ mutual fund on the prior notice is correct, please note that the Plan has not made either of these investments available to Plan participants. Please disregard information on these two funds. We apologize for any inconvenience" and call it a day. If the funds are included on enrollment materials, then I think you start a new clock.