Missing Participants or Beneficiaries
Plan sponsors, administrators and qualified termination administrators (QTAs) sometimes need to locate missing participants or beneficiaries. For example, correction of a plan failure under the Employee Plans Compliance Resolution System (EPCRS) may require payment of additional benefits to terminated participants. See Revenue Procedure 2013-12, 2013 I.R.B. 313.
Previously, IRS provided letter-forwarding services to help them locate missing plan participants, but with the August 31, 2012 release of Revenue Procedure 2012-35, IRS will no longer forward letters for that purpose. IRS will continue to process requests postmarked before August 31, 2012, but will not process any new request after that date to find plan participants or beneficiaries. However, IRS does plan to issue Employee Plans Compliance Resolution System (EPCRS) guidance extending the correction period for plan sponsors and administrators affected by this program change.
Even in the absence of IRS letter forwarding services, sponsors, administrators and QTAs may use a variety of other methods to locate missing participants and beneficiaries, including:
- commercial locator services
- credit reporting agencies
- Internet search tools
- the Social Security Administration’s letter forwarding program