Employee Benefit Plan Alert: Minimum Distributions for Missing Participants

By Rita Piazza  |  December 13, 2017

The Internal Revenue Service’s (IRS) Employee Plans Examinations division issued a field directive to all exam agents on missing participants, beneficiaries and the required minimum distribution (RMD) standards under Internal Revenue Code Section 401(a)(9).

The memo directs Employee Plan examiners not to challenge a qualified plan for its failure to commence or make an RMD to a missing participant or beneficiary if the plan has taken the following steps:

  • Searched plan and related plan, sponsor and publicly-available records or directories for alternative contact information;
  • Used any of these search methods:
    • a commercial locator service;
    • a credit reporting agency; or
    • a proprietary internet search tool for locating individuals; and,
  • Attempted contact via U.S. Postal Service certified mail to the last known mailing address and through appropriate means for any address or contact information (including email addresses and telephone numbers).

If a plan hasn’t completed the steps above, Employee Plan examiners may challenge a qualified plan’s violation of the RMD standards for its failure to commence or make a distribution to a participant or beneficiary to whom a payment is due.

About Rita Piazza

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Rita Piazza, CPA, MBA, is a Senior Director in the Professional Standards Group at Marks Paneth LLP. She serves on a team that is responsible for the final release of audited, reviewed and compiled financial statements including pension plan audits, projections and forecasts and agreed-upon procedures. Ms. Piazza has also been involved with training the audit staff and keeping the firm's professionals apprised of current technical pronouncements in accounting and auditing. She has a particular... READ MORE +

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