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The Locate and Notify Standard

Finding a retirement plan participant pays nothing. No fee, no asset, no product. That is why the work goes undone, and why it cannot be left to goodwill. This is the standard we are asking for.

  1. 1.Make the federal registry complete.

    Convert voluntary submission to the Retirement Savings Lost and Found into mandatory annual reporting tied to Form 5500. Extend eligibility below age 65. Include state and local plans.

  2. 2.A locate and notify standard before any balance moves.

    No balance should be escheated, terminated by force-out, or transferred to a default IRA until the fiduciary has documented a prescribed search sequence. Set the trigger at five years without contact and require the search record to be retained and auditable.

  3. 3.Stop premature state seizure.

    Support the SAFER Act of 2026, which would require confirmed death or extended verified no contact before escheatment and bar inactivity alone as a trigger. Oppose shortening dormancy periods to three years. Require states to report back to the plan when a claim is paid.

  4. 4.Fix the tax treatment.

    Direct the IRS to issue withholding and reporting guidance when a balance is transferred to a state unclaimed property fund, the gap the Government Accountability Office identified in 2019 and which is still open.

  5. 5.Pay for the work.

    Asset-based compensation pays nothing for finding a person. A dormant balance generates no fee, so the search has to be a fundable plan expense rather than an advisor's unpaid hours. Confirm that participant location services are a reasonable and payable plan expense, and require participant location activity to be disclosed in plan reporting so it is visible.

  6. 6.Data standards.

    Set minimum census data standards: address verification at defined intervals, Social Security number validation, and reconciliation between payroll, human resources, and recordkeeper systems.

  7. 7.Beneficiary designations.

    Require plans to confirm beneficiary designations at enrollment, at separation from service, and on a recurring cycle, and to tell the participant who is currently named. Courts have held that a plan's documents and recorded designations control.

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The Locate and Notify Standard

Tene Morgan leads the team that does this work at Navigant Advisory Group.

Senior Manager, Client Strategy & Experience

Tene Morgan

Tene Morgan

Senior Manager, Client Strategy & Experience

Tene Morgan leads client strategy and experience at Navigant. She spent more than thirteen years managing programs and relationships across nonprofit, higher education and consulting settings, most recently as Assistant Director of TRIO Upward Bound, where she coordinated student services, staff, partners and summer programming.

She holds a Master of Global Affairs from the University of Notre Dame's Keough School of Global Affairs, completed in 2023, with a specialization in human-centered instructional design.

She applies that training directly: organizing the information clients need, facilitating conversations, designing onboarding and review processes, and translating complex retirement topics into plain language.

Her focus is the part of the experience people actually feel. What a participant understands after a meeting. Whether a plan sponsor can find an answer without calling three times. Whether the process holds up the same way every time.

Leading the work of locating missing participants takes the same discipline: finding the person, confirming who they are, and making sure they understand what they have.

"I spent thirteen years designing programs for students who were the first in their families to go to college. The question was always the same: does the person in front of me actually understand what they're being told. Retirement plans are no different."