A challenge that all plan fiduciaries and their advisers face is how to deal with “lost” participants. When investigating a plan, the Department of Labor (DOL) will focus on how the plan addresses that. Indeed, the DOL recently challenged practices thought by plan fiduciaries and their advisers to be appropriate under the Employee Retirement Income Security Act (ERISA). Given this scrutiny, plan sponsors and their advisers should examine how their plans and service providers resolve the issues involved.
In the PLANADVISER article linked below, Groom principal David Kaleda provides further details about these challenges and offers some ideas on how to address these issues in the absence of further guidance.