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Where, oh where, have my retirement benefits gone?

“I have a client who has worked in the banking industry for decades and has changed jobs numerous times. Many of his former employers have merged with other institutions or no longer exist. He is not currently receiving any retirement benefits from these past employers, but feels certain he should be. How can he locate his lost retirement plan benefits?”

ERISA consultants at the Retirement Learning Center (RLC) Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare. We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with a financial advisor from New Jersey is representative of a common inquiry related to locating lost retirement plan benefits.

Highlights of the Discussion

Given the frequency with which the average U.S. worker changes jobs throughout his or her career (i.e., 12 times)[1], and the merger and acquisition activity in the past decades, it should not be surprising that some workers have lost track of their retirement plan assets. The Employee Retirement Income Security Act of 1974 (ERISA) requires plan sponsors to make efforts to find missing plan participants.[2]

Former participants can take matters into their own hands and search for retirement benefits to which they believe they are entitled. Below is a list of options for locating lost retirement plan assets. There may be other resources as well.

  1. Contact former employer(s) directly if they still exist. Check old tax forms, Forms W-2 and other employment-related documents.
  2. Contact the plan’s recordkeeper or third-party administrator (TPA). This information likely appears on an old plan statement, if available.
  3. Search the Department of Labor’s (DOL’s) Form 5500 database of filings (Form 5500/5500-SF Filing Search) for plan administrator contact information. Many qualified retirement plans are required to file this annual plan report with the IRS and DOL. Using the employer’s tax identification number may be helpful in locating employers and plans that have been merged or changed names.
  4. Try the DOL’s searchable database of abandoned plans, which contains information on retirement plans that have been forsaken by their sponsors.
  5. The Pension Benefit Guaranty Corporation (PBGC) has two ways to assist in benefits searches. First, search the PBGC’s database for unclaimed defined benefit plan pensions. Searchers can also try to locate a plan by whether it is insured or trusteed by the PBGC. Second, search the PBGC’s list of missing participants. As of January 1, 2018, terminating defined contribution plans have the option of transferring missing participants’ benefits to the PBGC for eventual distribution.[3]
  6. Every state has some type of unclaimed property program. Plan sponsors who have failed to locate missing participants or beneficiaries may have escheated the retirement plan assets to their respective state programs. The National Association of Unclaimed Property Administrators is a not-for-profit organization that maintains a database of state programs to help individual’s find missing property.
  7. Searchers could check with The National Registry of Unclaimed Retirement Benefits to see if a former employer has listed a particular person as a missing participant. The registry is a nationwide, secure database listing of retirement plan account balances that have been left unclaimed.
  8. Watch for a notice from the Social Security Administration (SSA): Potential Private Retirement Plan Benefit Information. It is a reminder about private employer retirement benefits that an individual may have earned, also called “deferred vested benefits.” The IRS provides the information to the SSA. It comes from the plan administrators of the private retirement plans in which workers participated.
  9. The nonprofit organization Pension Help America may be able to link searchers with local and regional governmental offices to help locate retirement plan assets and/or solve other benefit issues.

Conclusion

Individuals who have lost track of their retirement plan benefits for whatever reason have several federal, state, regional and local resources available to help them find the retirement benefits to which they are entitled.

[1] https://www.bls.gov/news.release/pdf/nlsoy.pdf

[2] https://www.irs.gov/retirement-plans/missing-participants-or-beneficiaries

 

[3] https://www.pbgc.gov/prac/missing-p-defined-contribution

 

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