Frozen DB

[thepensionmaven]

We administer a “ hard frozen” plan. Many of the participants terminated recently, and they can not be found. Since these are NHCEs, and are past the plan’s NRA, they are entitled to actuarial  increases in accrued benefits.  In the case of a frozen plan, where participants not only can not be located, but are past NRA, how would the RMD be calculated and who is entitled to receive, assuming the beneficiaries can not be located, as well?

 

 

[Effen]

First, doesn't matter if they are HCEs or NHCEs - all TVs should receive a rollup.  

If you have a SSN, you should be able to locate them via many inexpensive search companies - Berwyn Group & Penchex to name a few.

You can't pay the RMD unless you know where they are.  See attached conversation