While the Department of Labor (DOL) has been focusing on missing participants, expect them to question plan sponsors about missing participants and the automatic rollover provider that they use. Why? Because I was asked that question for a plan sponsor on an audit and I assure you, saying to pick the automatic rollover provider just because the third party administrator (TPA) you use, uses them isn’t a valid reason.

I think in the future, plan sponsors are going to have to review their automatic rollover provider, how they were hired, and what fees they collect. In addition, I think DOL may look at the stable value product that these rollover funds are in, and raise concerns on how little these missing participant account holders are collecting in this fund.