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Posted

Any solutions anyone knows about?

Annual check to the state as an escheat process?

Failure to make the RMD is a problem for the plan as well as the Participant I believe.

Thanks

CBW

Posted

"Failure to make the RMD is a problem for the plan as well as the Participant I believe."

Yes, and this is why the lost participant circumstances need to be addressed timely and completely, not just with each year's required distribution. The first place to start is the plan document. A common approach is to forfeit the account balance. You should also become familiar with Field Assistance Bulletin 2014-1; it deals with plan terminations but has broader implications.

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