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SSA Letter Forwarding Program to End May 19, 2014

Posted Monday, May 19, 2014 by Linda M. Josephson

Effective May 19, 2014, the Social Security Administration (“SSA”) is discontinuing its letter forwarding program, following the lead of the Internal Revenue Service (“IRS”), which discontinued its letter forwarding program in 2012. These services had long been considered the “gold standard” for qualified plans seeking to locate lost participants and beneficiaries. Their termination leaves plan sponsors with only commercial locator services going forward.

ERISA requires plan sponsors to take steps “reasonably calculated to ensure actual receipt” of certain notices and communications. Additionally, as noted in the IRS’s correction procedures (“EPCRS”), full correction of an operational misstep requires qualified retirement plan sponsors to undertake a diligent search for affected participants. This begins with mailing to the individuals’ last known mailing address and culminates in use of a commercial locator service.

Plan sponsors that have incorporated SSA’s letter forwarding program into their administrative procedures or policies to meet their ERISA obligations should review and update those procedures accordingly.