Best practices - finding missing participants and processing participant deaths

[StaceyHelton]

I've worked on the TPA side (or PBGC field benefit administration) in Defined Benefits for over a decade, but I've been out of day-to-day administration for the past few years. I'm now on the client side working to help improve procedures with our TPA, clean up records, and various de-risking projects.

With the DOL now cracking down on plans that do not do enough to find missing participants, we are in the process of working with our TPA to improve some of the processes they use to administer our pension plan.

What are your best practices for finding missing participants (or finding out if they are deceased)? What resources do you use? Do you have different amounts of work you do based on the age and status of the participant? For example, young (not near NRD) term vested participant / term vested nearing NRD / term vested nearing 70.5. How often do you try to find missing participants? Do you review them all at the same time, or on a schedule based on when they became “missing”? Do you do more if the person is in payment status and their payment is suspended due to uncashed checks?

What are your best practices for processing a death notification? Do you accept notification of death from financial institutions (for example, a direct deposit is returned with a notice that the account holder is deceased)? What other notifications do you accept? Do you utilize the internet and search obituaries? What free versus paid resources do you use (free being defined as only taking someone’s time)? What do you do for participants that you think are deceased but are not on the Social Security Death Index and you may not have received a notification?

If you are at a TPA, are there things that your company does not do and sends to the client to do instead?

Are there checklists you use for either process that you would be willing to share?