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Text of EBSA Compliance Assistance Release 2021-01: Terminated Vested Participants Project -- Defined Benefit Pension Plans
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL] Link to more items from this source
[Official Guidance]
Jan. 12, 2021

"The purpose of this memorandum is to ensure consistent investigative processes and case-closing practices among [EBSA's] Regional Offices conducting Terminated Vested Participants Project (TVPP) audits and to facilitate voluntary compliance efforts by plan fiduciaries.... The TVPP has three key objectives for defined benefit pension plans. First, to ensure these plans maintain adequate census and other records necessary to determine (a) the identity and address of participants and beneficiaries due benefits under the plan, (b) the amount of benefits due under the plan, and (c) when participants and beneficiaries are eligible to commence benefits. Second, to ensure these plans have appropriate procedures for advising participants with vested accrued benefits ('terminated vested participants' or 'TVPs') of their eligibility to apply for benefits as they near normal retirement age and the date they must start required minimum distributions (RMDs) under federal tax law. Third, to ensure these plans implement appropriate search procedures for terminated participants and beneficiaries for whom they have incorrect or incomplete information.... [This Compliance Assistance Release provides guidance for Regional Directors about:] Opening the investigation ... Information we ask for ... Errors we look for ... How cases are closed."

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