Automatic Rollovers for those who do not respond

[Guest EPS2]

We have been having the most difficult time with rolling over money for participants that do not respond to their termination packets.

It seems that every financial institution wants the participant's signature on their paperwork for compliance reasons. If we could get the participants signature, it would be on the termination paperwork...they won't respond.

...and doesn't this put the plan in jeopardy since these amounts are not being rolled over?

What do you do?

[Below Ground]

There are a number of financial institutions that will set-up an IRA for a person, under the authority of the Trustee. (See insurance companies that work heavily with plans, if nothing else.) These accounts typical use the employer's address, or last address of record for the person. Paperwork is completed and signed by the trustee. Signature of the participant is not needed.

I suggest that you use the "IRS Locator Service" to contact missing people. Social Security also has a similar service for use. In any event, document that efforts were made to locate the person and/or set-up the IRA. Finally, if concerned about compliance with plan terms, maybe you should look into removal of "automatic rollovers". Just use the $1,000 threshold for cashouts.

Just some thoughts on the subject.