Missing Participant

[Randy Watson]

We have a missing participant who should have received her first minimum required distribution last year. We have not had any luck locating the individual through the suggested search methods (certified mail, letter forwarding programs etc...). The failure to distribute a MRD seems to be an operational failure. Then again we are technically following the terms of the plan in attempting to locate this individual so that we can make the distributions. If we do have a failure how can we possibly correct it while the individual is still missing in action?

There are no plans to terminate the plan any time soon. Any suggestions on how to deal with this (other than suggesting additional search methods)? Thanks.

[Guest mjb]

Doesnt the plan forfeit benefits of missing participants which are payable, subject to restoration if the participant turns up at a later date? If not add it.

[Randy Watson]

That's fine, but does that somehow "correct" the MRD/qualification failure?

[david rigby]

If not located, consider the possibility that the individual is deceased. Then you have to look to the plan for beneficiary issues.

[Guest mjb]

How can you have a failure if you dont know where to send the payment or whether the participant is alive? Heirs of deceased participants frequently are not aware of benefits owed to deceased participants by prior employers. This is why benefits should be rolled over to an IRA after ternimation.