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Posted

I have seen a number of slides of talks on plan terminations and pension briefs that address the location of missing participants. Each one contains language such as:

"Use Free Electronic Search Tools. A fiduciary must make reasonable use of Internet search tools that do not charge a fee to search for a missing participant. Such online services include Internet search engines, public record databases (such as those for licenses, mortgages and real estate taxes), obituaries and social media."

Not one -- and I mean not one -- ever gives any examples, websites, etc. They either hold this information to themselves as top-secret information they will gladly sell you, or they don't know of any -- they simply believe there's got to be some!

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

Posted

I took it to mean Google and the like and if that didn't work you had to decide if it was prudent to spend money doing other searches. But maybe I'm wrong.

Posted

Finding those who have gone for their non-financial reward is reasonably achievable. Locating former employees whose name is John Smith and who live out of their cars is not so doable. Unfortunately, the IRS and SSA discontinued a great tool -- the mail forwarding service. They had no need to discontinue. Just charge more!

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

Posted

Sorry to be so negative but normally the folk you can't locate are assembly line workers who were employed in a factory in Cabool, Missouri and who sign their name with an "X." We likely could readily find anyone who reads this post via one of the suggested internet social media websites.

We've dealt on occasion with former employees who subsequent to their employment became guests of their state penal institution. They are very adept at making themselves scarce. If they have an identity, it's possibly not their own!

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

Posted

under Field Assistance Bulletin 2014-01 it says:

However, other more expensive approaches may be required when the account balance is large enough to justify an additional plan expense and other efforts have failed.

Accordingly, this Bulletin eliminates the requirement in FAB 2004-02 to use the discontinued IRS letter-forwarding service or the SSA letter-forwarding service. In their place, the required search steps have been expanded to include the use of electronic search tools that do not charge a fee.

Additional Search Steps
If a plan administrator follows the required search steps, but does not find the missing participant or beneficiary, the duties of prudence and loyalty require the fiduciary to consider if additional search steps are appropriate. A plan fiduciary should consider the size of a participant’s account balance and the cost of further search efforts in deciding if any additional search steps are appropriate. As a result, the specific additional steps that a plan fiduciary takes to locate a missing participant may vary depending on the facts and circumstances. Possible additional search steps include the use of Internet search tools, commercial locator services, credit reporting agencies, information brokers, investigation databases and analogous services that may involve charges.

Posted

I'm still waiting (and annoyed because it hasn't happened) for this to all be shifted over to the PBGC. One-stop repository/shopping, and an end to all this foolishness.

When I'm elected dictator, there are going to be some changes!!!

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