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QJSA Annuity-Terminated Plan with Unresponsive Participants


BTH

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In a DC plan subject to the QJSA requirements (merged MP assets) that has terminated, if a participant is unresponsive or cannot be located, what is the best option for account balances of over $5,000?  Are there insurance companies that will set up a QJSA without a participant's signature?     Or is it allowable/easier transfer the funds to the PBGC under their Missing Participant Program?    Thanks for any input.  

 

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Insurers can and do write QJSA contracts for missing participants - terminating DBPs are faced with that a lot - but those are pieces of larger contracts. I think you'd have a very hard time finding an insurer to write one contract, but I don't know that. 

Yes, I think turning over to PBGC would be the best alternative and, if this were a DBP in the same situation, would likely be the only viable alternative. In the DBP space, the PBGC views an unresponsive participant as a missing participant, but I don't know if they make the same leap for DC plans.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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