Termination of Employment

[Guest BR58W]

Trying to get a feel for how other multiemployer plans determine whether a participant has terminated employment for purposes of mandatory cash-out distributions. Our work is seasonal, so if a participant doesn't apply for benefits, we really can't conclude that he/she has terminated employment until no contributions are received for several months.

To my knowledge, there is no guidance on this topic and multiemployer plans are free to devise their own procedures for making this determination. The "no contribution" range that I have seen is between six months and two years.

Any other methods to consider? Any guidance that you're aware of? Any thoughts on the appropriate "no contribution" range?