Two participants with the same SSN

[Guest TPA Guy]

We have an interesting issue that some of you may have dealt with before. I haven’t. Plan A has a participant with the same SSN as a participant in a new plan that has just been brought on, plan B. We have confirmed with both plan sponsors that the ssn’s for these two individuals are accurate. We’ve also looked up the ssn through our locator service and there were 50 different aliases using that ssn!!! What do we do? The name for the participant in plan A has been overridden by the name of the new participant in plan B. They will both now have access to both plans since they have the same ssn. The participant in plan A is terminated but has a balance. 100% vested Safe Harbor money only.

[Lou S.]

It is the same person or one of them is lying.

We had this happen once but in one case the SSN was for the owner (or owner's son) of company A and was correct.

In the other, company B, it was a false SSN for a worker of questionable leagal status, so it was easy to insist that company B provide a corrected SSN which I think they did. This was easily 10 years ago but we ran into similar problems as you are experiencing.

Not sure what to do in your case.

[GMK]

Maybe plan sponsor A and plan sponsor B could use the USCIS E-Verify system to sort this out ... might be worth a try. All they need is the information from the form I-9 the employee provided when hired.

[Guest TPA Guy]

Good idea. We will ask them use E-Verify!

[david rigby]

Don' assume one of them is lying. Might be both!

[GMK]

I agree, David.

I thought about saying that, too, but I figured mentioning an I-9 will cause enough concern, where appropriate.

[Peter Gulia]

TPA Guy, each plan's administrator might consider instructing the recordkeeper to turn off computer access to each account that is a subject of a records mismatch, at least until some reasonable time after the records are adjusted.