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Finding Missing Participants: Ideas and Warnings

Finding missing participants serves a plan and employer well for a variety of reasons. But that doesn’t mean it’s an easy process — nor one made as clear by federal guidance as some may wish. A recent column suggests some best practices for performing this function.

In “Make Sure You Take Sufficient Steps to Find Missing Participants,” Arris Reddick Murphy, senior counsel with FedEx Corp.’s Tax & Employee Benefits Law group, discusses what must be done in this process as well as what can be done.

Steps to take when a plan administrator realizes a plan participant is missing, says Murphy, include:

  • Send a notice to the participant’s last known address via certified mail.
  • Check plan and employer records to see if there is an updated address for the participant.
  • Contact the designated plan beneficiary to see if he or she can provide updated contact information.
  • Use free electronic search tools to find an address for the lost participant. These include online search engines, public records databases, social media and obituaries.

Murphy offers some further ideas and suggestions regarding caution that should be exercised. “It is important to establish procedures for advancing the search for a missing participant using information obtained from social media,” she writes.

And if those efforts fail, Murphy outlines additional steps that can be taken, including obtaining the assistance of commercial locator services, credit reporting agencies, information brokers and investigation databases.

Murphy argues that an employer and plan administrator should exercise care. For instance, she says, it is probably a better idea to contact the leader of a club to which a missing participant belonged than to go to one of its meetings to encounter that individual. Further, she suggests that if those searching for a missing participant decide to subscribe to a public records database, they consider working with the employer’s legal department to do so.