On January 12, 2021, the U.S. Department of Labor (“DOL”) issued three pieces of informational guidance concerning plan sponsor obligations regarding missing participants: (1) a “best practices” document1, (2) Compliance Assistance Release 2021-012, and (3) Field Assistance Bulletin (“FAB”) 2021-013. Although this DOL information does not apply to governmental plans, it could have two key implications for governmental plans. First, although some states have laws governing their governmental plans, not all do, so this guidance can provide ideas for a missing participant process framework at a governmental plan. Second, service providers to governmental plans are likely to import all or some of their lessons from private sector plans to their governmental plan clients.
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- May 5, 2021 Create Date
- August 31, 2023 Last Updated
