I’m not afraid of many things, except making the deep water and the heights. I’m not afraid of the Department of Labor (DOL) because I listen to what they’re trying to say. So if they say that missing participants are a concern, I’m going to advise my clients to put processes in place to find missing participants and use rollover custodians like Millennium Trust when the accounts meet the rollover limits.
The DOL is focusing because most plans do nothing with missing participants until they need to terminate the plan. As a plan sponsor, you want to roll out former participants because they can be a compliance headache, especially since they tend not to get any information on the plan and may have a required minimum distribution if they’re around the magic age of 70 ½.
So if the DOL is trying to focus on missing participants, it’s important that you do as well. It’s always important to pick up social cues from our friends at the DOL.