For pension fund administrators, locating missing participants is one of the most persistent operational challenges in plan management. Defined benefit plans often carry decades of participant history and over time, individuals move, change contact information, retire quietly, or simply lose track of benefits earned earlier in their careers. The responsibility for closing that gap falls on the plan.
Unresolved participant records do more than delay benefit payments. They inflate administrative workload, complicate annual reporting, and create audit exposure when plans cannot demonstrate that meaningful, documented search efforts were made. For defined benefit plans subject to ERISA’s strict fiduciary standards, that documentation trail matters enormously.
A Shifting Regulatory Landscape
The regulatory environment around missing participants has changed in ways pension administrators need to understand, and not all the changes reduce your obligations.
In January 2025, the DOL’s Employee Benefits Security Administration issued Field Assistance Bulletin No. 2025-01, establishing a temporary enforcement policy that allows retirement plans, under specific conditions, to transfer benefit payments of $1,000 or less owed to missing participants to state unclaimed property funds, after reasonable search efforts have been made and certain protective conditions are satisfied.¹
More recently, EBSA announced a significant overhaul of its national enforcement priorities for FY 2026. The agency scaled back its direct enforcement focus on missing participants in 401(k) plans, redirecting those cases to the Retirement Savings Lost and Found Database, a centralized tool established under the SECURE 2.0 Act of 2022 that allows individuals to search for retirement benefits owed to them by former employers.²
Pension administrators should not interpret reduced enforcement activity as reduced responsibility. The Lost and Found database is designed solely to help participants find plan sponsors, plan administrators are not permitted to use it to locate missing participants.³ The proactive, documented search obligation under ERISA remains fully in place.
The Scale of the Problem
The numbers make clear that missing and unlocated participants represent a significant and ongoing liability across the defined benefit landscape. In FY 2025 alone, EBSA helped 8,015 terminated vested participants in defined benefit pension plans collect $512.5 million in benefits owed to them.⁴
That figure reflects cases that had already gone unresolved long enough to require regulatory intervention. For plan administrators, the better outcome is never getting there in the first place.
Transferring small balances to unclaimed property funds addresses a narrow category of cases administratively. But for the broader universe of missing participants in defined benefit plans where benefit amounts are often substantial and annuity payments may have been accumulating for years that option provides little practical relief. These individuals may not know a benefit exists, let alone know to search a federal database for it.
How Abacus Intel Helps Plans Stay Ahead
Abacus Intel helps pension fund administrators find missing participants and verify mortality events before unresolved records become fiduciary or operational problems. Our solutions combine trusted data, advanced analytics, and expert research to identify missing individuals, locate beneficiaries, and verify U.S. mortality events with 99% accuracy, every day, at an average cost 25% lower than other providers.
Request a demo here to see how Abacus Intel can help your plan locate missing participants, reduce liability exposure, and deliver benefits with confidence.
Citations
¹ U.S. Department of Labor, Employee Benefits Security Administration. Field Assistance Bulletin No. 2025-01: Missing Participants and Beneficiaries — Small Retirement Benefit Payments Transferred to State Unclaimed Property Funds From Ongoing Pension Plans. January 14, 2025. https://www.dol.gov/agencies/ebsa/employers-and-advisers/guidance/field-assistance-bulletins/2025-01
² 401k Specialist Magazine. DOL Enforcement Overhaul Reshapes 2026 Priorities. January 28, 2026. https://401kspecialistmag.com/dol-releases-2026-enforcement-projects/
³ International Foundation of Employee Benefit Plans. Missing Participants: Help From SECURE 2.0 and the Latest Best Practices. February 2024. https://blog.ifebp.org/missing-participants-help-from-secure-2-0-and-the-latest-best-practices/
⁴ ASPPA Net. What Did EBSA Enforcement Mean in 2025? February 2, 2026. https://www.asppa-net.org/news/2026/2/what-did-ebsa-enforcement-mean-in-2025/
