It’s more work, but it’s clear that the Department of Labor (DOL) wants you to do more work when dealing with former participants who you lose track of, but still have money in your 401(k) plan.
It’s important that you develop a process to identify missing participants and to find them. Use online searches to locate missing participants through free tools or pay for one of those inexpensive people searches.
You need to put plan policies and procedures in writing to ensure clear, consistent practices. and document the decisions, steps, and actions you have taken to implement the policies. The reason you have to is that the DOL is asking plan sponsors now about their missing participant procedure and it won’t look right if you don’t have an answer.
