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PBGC Final Regs on Missing Participants: Roadmap Emerges for Due Diligence
Morgan Lewis 
[Guidance Overview] Jan. 12, 2018
"[T]he PBGC consulted and coordinated with both the IRS and the DOL ... The three pieces of recent guidance ... DOL Field Assistance Bulletin (FAB) 2014-01 on Fiduciary Duties and Missing Participants in Terminated Defined Contribution Plans ... The PBGC Rule ... The IRS October 19, 2017 Memorandum ... can be viewed as a rough roadmap -- endorsed by all three agencies -- for plan fiduciaries trying to determine the appropriate due diligence steps to take with respect to missing participants."
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