101(f) Annual Funding Notice

[waid10]

We are almost ready to send our annual funding notice for the defined benefit plan. However, we cannot locate addresses for a handful of participants. We are searching. If we cannot locate them, what should we do? What is our responsibility regarding these participants?

[Andy the Actuary]

Start accruing potential penalty of $1,000 day for each you cannot locate!!!

It's no different from when ye olde SAR was sent. Plan should make legitimate effort, starting with sending to employee's last known address. You may also be able to locate by Googling name if sufficiently unique (John Smith no, Meloflous Noteinkey, probably) If returned, I would suggest looking into Social Security forwarding service: http://www.socialsecurity.gov/foia/html/ltrfwding.htm. There are possibly web-based services that might help.

[david rigby]

The IRS has a letter forwarding program. Free if 49 or fewer.

Expensive if 50 or more.

http://benefitslink.com/boards/index.php?showtopic=40445

[SoCalActuary]

We are almost ready to send our annual funding notice for the defined benefit plan. However, we cannot locate addresses for a handful of participants. We are searching. If we cannot locate them, what should we do? What is our responsibility regarding these participants?

Consider seriously the option of web posting this information. It would show a good-faith attempt to make the information available. Of course, you should also keep a record of your attempts to contact the missing ones.

[AndyH]

Start accruing potential penalty of $1,000 day for each you cannot locate!!!

A-Rod could pay 100 of those every day, 50 after taxes. Think about that for a minute.

[tymesup]

The pharmacist gets paid first.

[Guest Dan Moore]

Start accruing potential penalty of $1,000 day for each you cannot locate!!!

It's no different from when ye olde SAR was sent.

Speaking of SAR, does a DB plan sponsor who issued a 2008 101(f) notice also have to issue a 2008 SAR for the plan?