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Missing Participants and RMDs: Increased Enforcement, Alleged ERISA Violations, and Limited Guidance Cause Headaches for Plan Fiduciaries
Winston & Strawn LLP
[Guidance Overview] Feb. 27, 2018 "FAB 2014-01 is helpful guidance for administrators of terminating defined contribution plans, but more guidance is needed ... For example, would an ongoing plan be required to run the searches listed above every year while the participant remained missing? ... Contacting coworkers of missing participants will generally be appropriate only under limited circumstances ... Before benefits are forfeited, attempts to notify participants of the impending forfeiture must be made ... [R]ecords must be maintained that would allow those benefits to be reinstated if the missing participant or beneficiary is later located.... [U]nless the [PBGC] program is also expanded to ongoing defined contribution plans, the value ... to most plan administrators seems limited." MORE >> |
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