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PBGC Expands Missing Participant Program to Cover Defined Contribution Plans
Boutwell Fay LLP [Guidance Overview] Jan. 2, 2018 "The new [voluntary] missing participant program for DC plans ... is applicable only to terminating plans ... Although voluntary, the program [for a terminating plan that elects to be a 'transferring plan' meaning the plan elects to transfer benefits to the PBGC for distribution to participant] is 'all or nothing'. If a plan elects to be a transferring plan, it may not choose to turn over the accounts of some participants and not others. This anti-cherry-picking rule does not apply to [a terminating plan that elects to be a 'notifying plan' (meaning the plan elects to merely provide information to the PBGC about the disposition of participants' benefits)]." |
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