Retirement plan updates from DOL and IRS on missing participants and uncashed checks

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February 2021


The DOL issued three pieces of guidance to help retirement plan fiduciaries meet their obligations under the Employee Retirement Income Security Act of 1974 (ERISA) to locate and distribute retirement benefits to missing or nonresponsive participants.   The IRS also recently has weighed in on issues affecting missing participants, publishing guidance on withholding and reporting requirements where uncashed checks are escheated to a state’s lost property fund, as well as late rollover relief for a participant who recovers a plan distribution from a state unclaimed property fund.

The takeaway

This new guidance is helpful in that tax-qualified plans with missing participants now have definitive steps they can take in seeking to track participant populations and satisfy potential DOL investigators.  However, it is unclear how many of the steps that the DOL outlined are required to be undertaken by a plan sponsor in order to obtain the DOL’s approval of its processes.

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Carrie Duarte

Workforce of the Future, Deals Leader, PwC US

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