"Company X sponsors a 401(k) plan. Participant A terminates employment in 2025 with an account balance of $6,985. X directs X's account balance to be cashed out. A couple months later, based on favorable investment performance, a check is issued to A for $7,055. Has the 401(k) plan committed an operational failure by issuing a check to a former employee for more than the cashout threshold?"

"One of our client's is a doctor who sponsors a DB Plan for his medical practice. The plan is not terminating and is not covered by the PBGC. We are in the process of cashing out several terminated participants. One of these former employees has a benefit worth much more than $7,000. She is married and has received her distribution election forms. However, she is not cooperating and will not return her forms. In accordance with statute and with the plan document, the default form of benefit is a joint and survivor annuity. We have checked with several insurance companies, all of whom offer the desired annuity. However, every insurance company wants a signature from the participant. This is a catch 22 because this participant is not cooperating. [1] Does anyone know of an insurance company that will provide an annuity for the benefit of a terminated participant without the signature of that participant? [2] I have heard that the PBGC now permits limited use of their Missing Participant Program for plans that are not covered by the PBGC. This plan is not covered by the PBGC and this participant is not missing. Does anyone have information or experience using the PBGC Missing Participant Program for this type of situation?"