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DOL Guidance on Missing Pension Plan Participants
Verrill Dana LLP Link to more items from this source
[Guidance Overview]
Jan. 22, 2021

"Although FAB 2020-1 provides relief for plan fiduciaries and QTAs to use the PBGC Missing Participant Program, it does not preclude the DOL from pursuing violations of ERISA for a plan fiduciary's failure to [1] maintain adequate plan and employer records and [2] diligently search for participants prior to a transfer of accounts to the PBGC.... [P]lan fiduciaries should establish procedures described in the DOL's Best Practices guidance and use the PBGC's Missing Participant Program for participants and beneficiaries that cannot be located only after the fiduciaries have completed diligent participant searches."

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