Consolidation Corner

Similar to the missing participant problem, plan sponsors face significant uncertainties when navigating the issue of uncashed distribution checks. On one hand, regulators increasingly view the existence of uncashed checks as a sign of fiduciary weakness – a red flag indicating that participants may not be receiving the benefits they are owed. On the other hand, plan sponsors must operate within a complex regulatory environment that provides limited direct guidance on how to handle these situations when they occur.

In this environment, it is vitally important that each retirement plan maintain a formal, documented and defensible uncashed distribution check policy – one that outlines the plan’s procedures, establishes consistent practices and mitigates fiduciary risk.

New Year’s Eve and New Year’s Day remind us that, no matter what happens in our lives, or how much we might want to slow down, the world continues to turn. No, this column is not a plug for the defunct soap opera As The World Turns. It is instead a reminder that, with each passing year, life not only goes on, but the Americans born today will be part of future generations that will grow up with more technological advancements than those who came before them.

During 2025, important developments emerged related to the topic of retirement savings portability, including auto portability. Taken together, they represent a breakthrough year for portability, including:

When plan sponsors consider missing participants, their predominant emotion is likely to be frustration – driven by a caseload of missing or unresponsive participants that defy resolution. As an administrator of IRAs, a 401(k)-plan sponsor and a provider of commercial search services, we understand completely.

October has been a phenomenal month for auto portability, with plan sponsor adoption surging and industry thought leaders increasingly recognizing the promise of auto portability in finally solving longstanding 401(k) system portability issues.

In October, retirement industry media outlets urgently reported on updated research estimating that there are 31.9 million “forgotten” 401(k) accounts, totaling about $2.1 trillion in assets.

Several factors, including the gender pay gap, the education and economic gaps in communities of color, and the lack of plan-to-plan retirement savings portability for job-changers, have led to a serious retirement savings deficit in the U.S.

For almost two decades, industry analysts, policymakers, and retirement advocates have warned about the corrosive effects of 401(k) cashout leakage. Every year, billions of dollars that should remain invested for retirement instead vanish from the system when participants change jobs.

When American workers change jobs, the fate of their retirement savings is often left hanging in the balance – especially for those with smaller accounts of less than $7,000. Historically, this segment of retirement participants has faced an uphill battle, where complex transfer processes and the lure of “sudden money” have frequently produced cashouts that undermined their long-term retirement security.

But today, with the continuing adoption of auto portability via the Portability Services Network, the story is changing.

For too long, the promise of a secure retirement has eluded millions of hardworking Americans – particularly lower-income workers, women, and minorities. Despite the undeniable progress made through workplace retirement plans, the reality remains: a persistent retirement savings wealth gap threatens our nation’s most vulnerable populations.