Has anyone experienced a recent DOL audit concerning Required Disclosures to defined benefit plan participants at time of termination, periodic statements to deferred vested participants who have not yet reached NRA, and to participants once they reach NRA? In addition to a copy of the SAR and SPD documents, what do they audit to determine if we have complied with actually mailing out the documents? Apparently, there has been a complaint that we have failed to provide periodic statements (SAR, SPD, and benefit statements) to deferred vested participants by a participant whose address has not change in the 15 year period since he left the company (no excuse for bad address). The previous employee responsible for doing so worked here for over 25 years and basically documented nothing concerning the mailings. Could you please clarify exactly what documents are to be mailed to deferred vested participants, when and how often in a defined benefit plan and how proof of mailing each category should be documented. Thanks!
