May 2021

Missing...and Still Missing Participants: New Guidance From the Department of Labor

In the March/April edition of 401(k) Advisor, benefits and executive compensation partner Heather Abrigo and associate Betsy Olson co-authored an article in which they provided an overview of new Department of Labor (DOL) guidance that includes a variety of suggestions for plan sponsors and services providers on dealing with the issue of missing participants.

First, the authors detailed the DOL’s four best practices for pension plans and examples of red flags acquired during investigations, including some that relate to missing participants.

Second, Abrigo and Olson highlighted how the DOL issued Compliance Assistance Release 2021-01, which focused on the Terminated Vested Participants Project audits for defined benefit plans.

Third, they discussed Field Assistance Bulletin 2021-01 (FAB 2021-01), which the DOL issued as temporary guidance due to the impact of COVID-19 on plan administration and recordkeeping.

In conclusion, the authors noted, “It is important for plan sponsors to work with their service providers to ensure that the issue of missing participants is being discussed and, if necessary, the proper steps are taken to avoid any of the ‘red flags’ raised by the DOL in their guidance.”

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