When an employee leaves your company for any reason, it is important that we continue to maintain their most up-to-date contact information on file. Having complete and accurate records allows Guideline to respond to any requests by the Internal Revenue Service (IRS) or Department of Labor (DOL) in the event of a claim by the former employee or an audit of your plan, dating back up to 6 years.
One particular area of interest to the IRS in this regard is the plan’s compliance with the required minimum distribution standards for former employees. Additionally, the Employee Retirement Income Security Act of 1974 (“ERISA”) and current regulations require specific notices or disclosures to be furnished to eligible employees or plan participants, including those who have terminated, when certain events occur. If Guideline does not have accurate participant contact information, we rely on the plan sponsor to locate that individual and furnish them with important notices.
When an employee terminates employment, remind them to continue to monitor their account and keep their Guideline account information current just as they would with any other financial institution. This includes updating their physical and email addresses, phone numbers, and other important information.
Tips to locate a former employee
Here are several tips to help you contact a former employee regarding required plan information:
Try contacting the former employee using any available information, such as their last known physical or email address, phone numbers, designated beneficiaries, or emergency contact. An attempt to contact them using the United States Postal Service (USPS) should always be via certified mail to the last known mailing address.
Search publicly available records or directories for alternative contact information. For example, LinkedIn or other social media accounts can be effective in tracking down missing or unresponsive former employees.
If the above steps were not successful, retain a commercial locator (skip-tracer) search service or a proprietary internet search tool for locating individuals. Sponsors may retain their own search service or contact Guideline for assistance locating “missing” participants via a commercial search service selected by Guideline.