Best Practices to Find Missing Plan Participants

APRIL 1, 2025

Finding missing retirement plan participants is an ongoing — and necessary — challenge for employers. Whether your organization offers a defined contribution (DC) or a defined benefit (DB) pension plan, you have a fiduciary duty to find missing participants under the Employee Retirement Income Security Act of 1974 (ERISA).

The Pension Benefit Guaranty Corporation (PBGC) was the first federal agency to administer a program to hold retirement benefits for missing participants and beneficiaries in terminated retirement plans. The PBGC Missing Participants Program aims to help these participants and beneficiaries find and receive their benefits.

Follow Updated Guidance From the DOL and EBSA

The Department of Labor (DOL) has focused on the issue of missing participants for years, and works in conjunction with the Employee Benefits Security Administration (EBSA) to audit retirement plans and reinforce actions employers must take to locate lost participants and pay their benefits.

The DOL and EBSA have issued detailed guidance, including steps employers should take to locate missing participants:

The SECURE 2.0 Act of 2022 includes provisions to help participants locate their benefits in their former plans, and to minimize the number of missing participants:

• Auto-portability — If an employer agrees to join the auto-portability network, certain small retirement plan account balances for terminated employees that were automatically rolled into a default individual retirement account (IRA) from a prior employer’s retirement plan can be automatically rolled over to a new employer’s retirement plan, unless directed otherwise by the participant.
• Retirement savings lost and found — The DOL is creating a searchable retirement savings database to help individuals locate lost or forgotten retirement plan accounts.

Best Practices to Reduce Missing Participants

These EBSA best practices have been proven to reduce instances of missing or nonresponsive participants:

• Maintain accurate census information for the plan’s participant population. Periodically reach out to participants (current, retired and terminated) and beneficiaries to confirm or update their contact information such as email, home and business addresses, phone numbers, social media accounts and emergency contacts.
• Implement effective communication strategies. State upfront and prominently what the communication is about (e.g., eligibility to start payment of pension benefits, a request for updated contact information, etc.).
• Conduct missing participant searches. Check with designated plan beneficiaries and the participant’s emergency contacts (in the employer’s records) for updated contact information. Consider using a commercial locator service, a credit-reporting agency, or a proprietary internet search tool to locate missing individuals.
• Document procedures and actions. Document key decisions and steps taken to implement the policies.

These Searches Make Sense

Missing participants can also cause administrative burdens, increased plan costs and fiduciary risk for the organization. Here are reasons employers should address participant accounts:

• There are large amounts of money at stake. Each year, hundreds of millions of dollars are recovered for terminated, vested participants in retirement plans.
• Missing participants inhibit the ability to make timely required minimum distributions (RMDs), which may result in penalties to the employer and participant.
• Missing participants inhibit the ability to distribute death benefits to beneficiaries. This is another important reason to maintain up-to-date beneficiary election data.
• Missing participants may delay plan terminations, requiring another year of audit costs and governmental filings.