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I have gone a little squirrelly looking for this....

I have a non-electing church plan that offers annuities with a life contingency only (no lump sums or certains). The plan does not have QJSA language. The plan has several terminated vested individuals. These participants did receive the term vested notice at termination letting each one know what benefit options they have at NRA.

Since the plan is not subject to ERISA or QJSA notice requirements, where in the Code or regs. does it say that the plan is responsible to contact each participant when they are approaching NRA to elect their benefit? The only thing I could find where it is inferred is the lost participant regs. under 1.401(a)-14(d).


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