FSRA released their final guidance on Missing Members – Principles and Practices on December 10, 2020. The guidance outlines the principles and practices to assist pension plan administrators in searching for missing members. A plan member is considered missing if the plan administrator is unable to locate or communicate with the member and believes the address on record is no longer valid. The guidance outlines the responsibilities of the plan administrator and provides best practices to ensure accurate member records are up-to-date.
The guidance recommends that administrators employ a record management system that supports long-term administration of the pension plan. Special consideration should be given when personnel changes occur and during plan design changes, restructuring and transfers. In addition, the guidance offers best practices for communicating with members, including a range of communication and delivery methods, promoting member activity, emphasizing the importance of updating contacting information, communicating at various intervals, and more. The guide also provides suggestions when searching for missing members, including searching right away, using external expertise, and documenting the search process.
Finally, the guidance also provides some suggestions on dealing with missing members during a pension plan wind up. For instance, FSRA may accept bulk annuity purchases or transfers to another ongoing plan. Administrators may contact FSRA for additional approaches to missing members on plan wind up.