Defined benefit and defined contribution plans require a variety of communication statements and notices that are critical for participants to receive. These include Annual Funding Notices (AFN), Lifetime Income Illustration in Periodic Pension Benefit Statements, Qualified Default Investment (QDIA) Notices, Automatic Contribution Arrangement Notices, and Safe Harbor Notices to name a few. There is one challenge that all of these, and other pension plan notices have in common: ensuring deliverability of accurate and compliant communication to plan participants and beneficiaries.

On average, one in seven Americans change their address every year. This has a significant impact on maintaining accurate participant information as people easily forget all the places their address needs to be updated.

In our recent webinar, Annual Funding & Other Retirement Plan Notices, Mike Irey, Director of Operations at PBI Research Services, discussed the impact inaccurate and missing personally identifiable information has on locating a person. For instance, having a wrong or missing social security number is the hardest data to clean up and has the highest likelihood of not locating a person, while a missing or incorrect address of a participant is the easiest to correct and find. Prior to sending any notices or communication, it is critical to ensure that the data being used to communicate with participants is clean and accurate. This will result in higher deliverability rates, minimize returned mail, and lower the cost of communication and outreach.

Carly Grey, an Associate at Morgan Lewis, also shared insights around the Department of Labor (DOL) regulation and guidance as it relates to sending communication – highlighting requirements and identifying possible pitfalls, clarifying recent changes due to the CARES Act, and where she sees the DOL and IRS focusing as it relates to plan communication. In addition, Carly spoke to the requirements of electronic disclosures for these and other notices under the 2020 DOL guidance.

Carly also shared her predictions for 2022, including seeing DOL audits continuing to focus on missing participants, IRS audits continuing that focus on timely commencement of benefits, more participant plan fee litigation, additional guidance relating to lifetime income disclosures, and the possibility of seeing new retirement plan legislation.

Here’s the full recording of the webinar:

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