This package contains:

Form MP-200, Schedule A, and Schedule B

Missing Participants Program 

Filing Instructions

for

Defined Contribution Plans 

Terminating on or after January 1, 2018
Table of Contents

Overview..................................................................................................................................................1

What, How, and When to File.....................................................................................................................4

Line-by-Line Instructions for Completing Forms and Related Schedules

• Form MP-200 (Plan Information)..................................................................................................6

• Schedule A (Individual Information - Notifying Plans)....................................................................9

• Schedule B (Individual Information - Transferring Plans) ............................................................ 10

Appendices

• Appendix 1 – Defined Terms....................................................................................................... 13

• Appendix 2 – Diligent Search Requirement................................................................................. 15

• Appendix 3 – Common Filing Errors ........................................................................................... 16

• Appendix 4 – Paperwork Reduction Act Notice........................................................................... 17

Form MP-200 instructions
Overview

Form MP-200 instructions Page 3

Introduction

ThegoalofPBGC’sMissing Participants Program isto connect missing participants with their benefits from 

plans that terminated and closed out. 

Section 4050 of the Employee Retirement Income Security act of 1974 (ERISA) and PBGC’s Missing

Participants Regulation (29 CFR Part 4050 subpart B) govern the program for defined contribution (DC)

plans. Although the Missing Participants Program is mandatory for PBGC-covered defined benefit plans, 

for DC plans, it is voluntary.

The DC program and these forms and instructions apply only to DC plansthat terminate on or after

January 1, 2018. Instructions and forms for the other types of retirement plans covered by PBGC’s 

Missing Participants Program can be found on PBGC’s Missing Participants Program webpage.

Terminology

Although the program is referred to as the Missing Participants Program, it covers beneficiaries as well as 

plan participants. Throughout these instructions, we use the term missing distributee when referring to 

anyone covered by the program (i.e., a participant or a beneficiary). The term participant is used both 

when referring to the overall program and when referring to an individual who was a participant covered 

by the plan.

Appendix 1 provides definitions for terms used throughout these instructions. In general, the defined 

terms are capitalized to signal the reader to refer to Appendix 1 for more information. The convention of 

capitalizing the defined terms is not followed for a few frequently used defined terms (e.g., “we,” “you,” 

“participant,” “distributee”).

Eligible defined contribution plans

The Missing Participants Program for DC plans covers common types of DC plans; specifically Internal 

Revenue Code (Code) section 401(k) plans, profit sharing plans, money purchase plans, target benefit plans, 

employee stock ownership plans, stock bonus plans, and Code section 403(b)(7) plans subject to Title I of

ERISA. Some examples of plans not covered are governmental plans, church plans, and plans that cannot 

pay benefits to PBGC in cash. See 29 CFR § 4050.201 for the exact rules.

What’s New

The current filing requirements are almost identical to the prior filing requirements. Key changes 

include:

• Filings with more than five missing distributees – If there are more than five missing distributees, 

information about those missing individuals (i.e., information that gets reported on Schedule A 

or B, whichever is applicable) must be reported in a spreadsheet format. Plan-related information 

is still reported on a form. See the “How to File” section for more information.

• Post-tax contributions other than Roth – In situations where a portion of a participant’s account is 

attributable to post-tax contributions, other than Roth contributions, additional information about 

the nature of those contributions must be provided as an attachment. See Schedule B, line 4c.
Overview

Form MP-200 instructions Page 4

• Pre-Filing Consultation Available – PBGC staff is available to help filers, especially first-time filers, 

understand the filing requirements. During a pre-filing consultation, we will provide an overview 

of the process, share helpful tips on how to avoid common errors, answer questions, etc. To 

schedule a pre-filing consultation, email Missingparticipants@pbgc.gov. 

We encourage you to take advantage of this service, especially if you are transferring any DC 

accounts that are partially comprised of post-tax contributions (e.g., Roth contributions).

• Common filing errors – We have added a new appendix containing details about common filing 

errors. We encourage you to review this information before submitting your filing. We’ve also 

added an overview of those common errors at the end of this section.

Who counts as missing

In general, an individual is considered missing if, when the plan closes out, the plan doesn’t know the 

individual’s location (e.g., if a notice from the plan is returned as undeliverable). For purposes of these 

instructions, we use the term “Unlocatable” to describe a missing distributee in this situation. 1

An individual is also considered missing if:

• The individual did not return the necessary paperwork providing instructions about how

the payment should be made (e.g., by check or as a direct rollover to an IRA); or

• The individual did not accept a lump sum payment (see “Unaccepted lump sum

payments” below).

We use the term “Unresponsive” to describe a missing distributee in either of the two situations noted 

immediately above. Note that a missing distributee may be both “Unlocatable” and “Unresponsive.”

Unaccepted lump sum payments issued in conjunction with the plan’s termination

If a check issued to a distributee by the plan in conjunction with the plan’s termination remains uncashed 

by the “cash-by” date on the check or in an accompanying notice, e.g., a date prescribed by the bank or

the plan, the lump sum payment is considered unaccepted if the check is not cashed by that date. This 

“cash-by” date must be at least 45 days after the check is issued. If there is no prescribed “cash-by” date,

then the lump sum is considered unaccepted if it is not cashed by the check’s stale date.2 In these 

situations, the transfer amount must reflect the total value of the benefit without any reduction for tax 

withholding.3

1 There is a requirement to do a Diligent Search in an attempt to locate these individuals. See Appendix 2 for 

information about the Diligent Search requirements. 2 A check’s stale date is typically six months after the check’s payment date. See § 4-404 of the Uniform Commercial 

Code. Note that this date may vary by state. 3 In some situations, such as where there is a qualified termination administrator (QTA) of an abandoned DC plan (as 

defined under Department of Labor regulations at 29 CFR § 2578.1), it may not be practical to reflect the total 

value of the benefit in the amount transferred, and if so, it would be permissible for a filer to transfer to PBGC the 

net amount of the uncashed check. Filers in this situation should contact PBGC before submitting the filing.
Overview

Form MP-200 instructions Page 5

Transferring Plans vs. Notifying Plans

With respect to a missing distributee, a DC plan that choosesto participate may either:

• Transfer the distributee’s account balance to PBGC, or

• Send PBGC information about the financial institution where the account balance was 

transferred to enable PBGC to connect the distributee with their benefit.4

Plans in the former category are called Transferring Plans. Plansin the latter category are called 

Notifying Plans.

A Transferring Plan must transfer to PBGC the account balances for all missing distributees. This is 

sometimes referred to as the “all or nothing” rule.

The “all or nothing” rule does not apply to Notifying Plans. In other words, a Notifying Plan may 

choose to notify PBGC about the disposition of benefits for some, but not all, missing distributees. 

However, PBGC encourages Notifying Plans to submit information about all missing distributees as 

doing so will increase the likelihood of connecting distributees with their retirement benefits.

Obligations before filing

• Request a PBGC case number — You must request a PBGC case number in advance of

submitting your filing because the case number needs to be reported in the filing, and if

applicable, with the payment.

To request a case number, send an email to Missingparticipants@pbgc.gov with “Requesting 

case number for DC plan” in the subject line. In the body of the email, include the plan

sponsor’s name and address, the plan name, Employer Identification Number (EIN), plan

number, and a contact phone number. In addition, please report the date you anticipate 

submitting the filing.

Within three business days, PBGC will notify you of the case number assigned to your plan. In 

general, this notification will be made by email (and sent to the email address from which the 

request was sent).

• Diligent Search — You must conduct a Diligent Search in an attempt to locate distributees you 

believe are Unlocatable before reporting them as missing. For information about the Diligent 

Search requirements,see 29 CFR § 4050.204 and Appendix 2 of these instructions.

4 These instructions use the term “financial institution” to describe an entity, other than PBGC, holding a missing 

distributee’s defined contribution account. In some instances, PBGC expects that a Notifying Plan may transfer 

money for a missing distributee to a state unclaimed property fund instead of a financial institution. Such plans are 

encouraged to report information about those transfers as well.
Overview

Form MP-200 instructions Page 6

Abandoned plans

To the extent these instructions require certain information to be reported, Qualified Termination 

Administrators of abandoned plans that do not have a full set of records should complete Form MP-200 

and the applicable schedule with the best available information. Keep in mind that providing as much of 

the required information as possible will make it more likely that a missing distributee will be found and 

connected to their retirement benefits.

Administrative Fee

PBGC charges a one-time $35 administrative fee with respect to each missing distributee for whom the 

plan transfers a payment obligation of more than $250 to PBGC. No fees are charged for individuals:

• for whom the plan transfers a payment obligation of $250 or less to PBGC, or

• covered by Notifying Plans.

Contacting PBGC

If you have questions about how to complete a Missing Participants Filing for a DC plan, contact PBGC:

• By email: MissingParticipants@pbgc.gov

• By phone: (800) 453-9584. If you are deaf, hard of hearing, or have a speech disability, dial 7-1-1 to access 

telecommunications relay services.

Common Filing Errors

• Deceased participants — In situations where the missing distributee is a beneficiary:

‒ Not providing the required attachment, and/or

‒ Reporting the participant’s name and Social Security number (SSN) on Schedule A or B 

(whichever is applicable) instead of the beneficiary’s name and SSN.

• Roth accounts — Incorrectly classifying non-qualified transfer amounts as qualified (or 

vice-versa).

• Uncashed checks — In situations where the distributee is considered missing because they 

failed to cash a distribution check issued in conjunction with the plan’s termination, 

transferring an account balance net of amount withheld for taxes instead of the full 

account balance.

• Post-tax contributions other than Roth — Reporting that some, or all, of a missing 

distributee’s account is attributable to post-tax contributions when that is not the case.

Appendix 3 provides detailed information about these errors. 
What, How and When to File

Form MP-200 instructions Page 7

Whatto file

A Missing Participants Filing for a defined contribution plan includes Form MP-200 and whicheverschedule 

is applicable, A or B, as explained below:

Form/Schedule Used by Type of Information

MP-200 All participating plans Plan information

Schedule A Notifying Plans Individual information about transfersto 

financial institutions

Schedule B Transferring Plans Individual information about transfers 

to PBGC

With respect to Form MP-200, you may enter data directly into a PDF fillable/printable version of the form 

or print a blank pdf version of the form and applicable schedule and enter the data by hand.

With respect to Schedules A and B:

• If you are reporting information for more than five missing distributees, the Schedule A or B 

information, whichever is applicable, must be reported in a spreadsheet format (i.e., the information 

for each missing distributee is reported in a separate row and each required data element is 

reported in a separate column). The spreadsheet is submitted as an attachment to the filing.

A sample spreadsheet that may be used for this purpose is available on PBGC’s website. The 

spreadsheet is set up so that each required data element is reported in a particular cell and it also 

includes space for additional attachment information that is required. In addition, the spreadsheet

can be used to calculate totals that need to be reported on Form MP-200 (e.g., number of 

individuals, total transfer amount).

• If you are reporting information for fewer than six missing distributees, you may report the 

individual information:

‒ In a spreadsheet format (see above), or

‒ Directly on the “form-version” of Schedule A or B, whichever is applicable. With this 

approach, as is the case for the plan-related information reported on Form MP-200, you

may enter data directly into a pdf fillable/printable version of the form or print a blank pdf 

version of the form and applicable schedule and enter the data by hand.

Although the spreadsheet format is not required for these filings, you may find it useful 

because a spreadsheet can be used to calculate totals that you will need to be report on 

Form MP-200 (e.g., number of individuals, total transfer amount).

How/where to file

Before filing, the Plan Administrator or Qualified Termination Administrator (of an abandoned DC plan) 

must sign and date Form MP-200. You may submit the signed filing by email, U.S. mail, or a

commercial delivery service.

To file by email, scan a signed copy Form MP-200 and send the complete Missing Participants Filing (Form 

MP-200, applicable schedules and any required attachments) to Missingparticipants@pbgc.gov with 
What, How and When to File

Form MP-200 instructions Page 8

“Filing for case # [insert applicable case #]” in the subject line.

For the security of your data, PBGC recommends submitting your filing using PBGC | Powered By 

LeapFILE or password protecting your files and sending the password separately.

To file by mail orif using a commercial delivery service,send the complete filing to:

Pension Benefit Guaranty Corporation 

DC Missing Participant Program/DMC 

445 12th Street SW

Washington, DC 20024-2101

How to send payment

If you are required to submit payment as part of the filing, we encourage you to send funds electronically 

via www.pay.gov, a free and user-friendly Federal website from which you can make secure electronic 

payments directly to many Federal Agencies, including PBGC. Alternatively, you may send payment by

electronic fundstransfer(ACH or Fedwire) or paper check.

See the “Payment Instructions” section of the Missing Participants Program webpage for additional 

information about payment options, including addresses and information to be included with the 

payment.

When to file

The date for submitting a Missing Participants Filing, and for payment of any monies owed to PBGC, is no 

later than 90 days after all distributions are made to distributees who aren’t missing, or one year after the 

plan termination date, whichever is later.

Amended Filings

If, aftersubmitting a Missing Participants Filing, you discover that it is incorrect or incomplete, you must 

submit an amended filing.
Instructionsfor MP-200 (Plan information)

Form MP-200 instructions Page

Unless the instructions below indicate that an item may be omitted, all of the following information must 

be reported. (See exception re: abandoned plans in the Overview section). If you are filling out the form 

by hand, please print all information in uppercase.

Amended filings

If thisis an amended filing, check the box at the top of the form.

When amending a Missing Participants Filing, Schedule A or B (whichever is applicable) of the amended 

filing must contain complete information for all missing distributees including an amended filing code.

For example, if you report three individuals on the original Schedule B and subsequently discover that:

• One missing participant was inadvertently omitted, the Schedule B for the amended filing must 

contain complete data on all four missing participants.

• One previously reported participant is not entitled to a benefit, the Schedule B for the amended filing 

must contain complete data on the other two missing participants.

Part I — General Information

1 Plan information

a Enter the complete name of the plan as it appears in the plan document.

b Enterthe EmployerIdentification Number and the plan number.

c Enter the 8-digit PBGC case number assigned to the plan. If you have not yet requested a case 

number, you must do so before submitting the filing. For instructions on how to request a case 

number, see “Obligations before filing” in the Overview section.

d Enter contact information (e.g., name, company, address, email, phone) for the person 

PBGC should contact if we have questions about the filing. This could be the Plan 

Administrator, Qualified Termination Administrator, third-party administrator, etc.

e Check the applicable box to indicate whether the plan is participating in the missing

participants program as a Transferring Plan or a Notifying Plan.

Transferring Plans must transfer accounts for all of their missing distributees. Although PBGC 

expects most Notifying Plans will provide information on all of their missing distributees, there is 

no requirement to do so.

2 Number of missing distributees

• Transferring Plans — Enter the total number of missing distributees for whom benefits are being 

transferred to PBGC. (i.e., individuals reported on Schedule B). Transferring plans must provide a 

breakdown of those with accounts more than $250, and those with accounts of $250 or less.

• Notifying Plans – Enter the total number of missing distributees for whom accounts are being 

transferred to an entity other than PBGC (e.g., a financial institution). Do not include individuals 

who are not reported in this filing, on Schedule A.

Notifying Plans may omit the breakdown based on accountsize.
Instructionsfor MP-200 (Plan information)

Form MP-200 instructions Page

If this is an amended filing, complete item 3. Otherwise, skip to Part II if this is a Transferring Plan and skip 

to Part III if this is a Notifying Plan

3 Additional information re: amended filings.

If one or more individuals reported in the original filing is not reported in this amended filing, check 

the “yes” box. This could happen if, for example, you originally reported that an account had been 

established at a financial institution on behalf of a missing distributee, but later discovered that the 

individual previously received their benefit and that the account was established in error. Otherwise, 

check the “no” box.

Required attachment— If any previously reported individuals are no longer considered missing (i.e., if 

you checked the “yes” box), include an attachment reporting each such individual’s name, social 

security number, and the reason why the individual is no longer considered missing.

If thisis a Transferring Plan, complete Part II. Otherwise, skip to Part III.

Part II — Additional Information for Transferring Plans

4 Default beneficiary provision — If the plan provides a rule regarding who is entitled to a participant’s 

account in the event the participant dies with no valid beneficiary designation on file, check the “Yes” 

box and attach a copy of the relevant plan provision. Otherwise, check the “No” box.

5 Enter the Benefit Transfer Date

6 Amounts owed to PBGC for missing distributeesreported in thisfiling

a Enter the aggregate value of account balances being transferred to PBGC as of the Benefit 

Transfer Date. This is the sum of the amounts reported in item 5 of Schedule B for each 

missing distributee reported on a Schedule B.

b Enter the aggregate administrative fee. The fee is $35 for each missing distributee reported on 

Schedule B with an account balance over $250. To determine this amount, multiply $35 by the 

number reported in column (2) of item 2 of the Form MP-200.

c Enter the sum of items 5a and 5b.

If thisis an amended filing, complete item 7. Otherwise,skip to item 8.

7 Reconciliation

a Previously paid amounts — If this is an amended filing, enter the amount previously sent to PBGC 

in conjunction with prior filings for this plan.

b Underpayment/(Overpayment) — Subtract item 6a from item 5c and enter the result. If the result 

is greater than $0, thisis the amount that must be sent to PBGC. If the result is negative, PBGC will 

contact you to facilitate a refund of the overpayment.

8 Paymentmethod. Check the applicable box to indicate the payment method.
Instructionsfor MP-200 (Plan information)

Form MP-200 instructions Page

Part III — Certification

9 The information reported in this filing must be certified by the Plan Administrator or Qualified 

Termination Administrator (of an abandoned DC plan). To do so, the required identifying information 

(e.g., name of person certifying the filing and applicable contact information) must be entered and the 

applicable administrator must sign and date the filing.

In addition, check the applicable box to indicate if the individual certifying the filing is the Plan 

Administrator or the Qualified Termination Administrator.
Instructionsfor Schedule A (Individual Information - Notifying Plans)

Form MP-200 instructions Page 12

Notifying Plans must complete this schedule to report information about missing distributees whose 

defined contribution accounts were transferred to a financial institution.

If you are:

• Using a spreadsheet to report Schedule A information, complete item 1 of Schedule A, enter “See

attached” in item 2a (the space provided for the name of the financial institution), and leave the 

rest of the Schedule A blank.

• Entering information into the pdf-fillable form version of Schedule A and need to report 

information for more than two individuals, click the button labelled “Add another Schedule A.” 5

• Entering information on a hard copy of the “form version” of Schedule A by hand:

‒ Print all information in uppercase, and

‒ If you need to report information for more than two individuals, use additional Schedules A,

number each one consecutively and report the total number of Schedules A in the space 

provided at the top of the form. For example, if two Schedules A are needed, the top of the 

first schedule should show: “This Schedule A is # 1 of 2.”

Unless the instructions below indicate that an item may be omitted, all of the following information

must be reported. (See exception re: abandoned plans in the Overview section).

PartI — Plan/Financial Institution Information

1 Plan information – Enterthe same information reported in items 1a-c of Form MP-200.

2 Financial institution information – Enter the applicable identifying information about the institution to 

which you transferred DC accounts for missing distributees.

PartII — Individual Information

3 Missing distributee information — Enter the following information with respect to each missing 

distributee whose account was transferred to an entity other than PBGC. 

If the participant is deceased (i.e., if the missing distributee is a beneficiary), the information 

entered in lines 3a and 3b should relate to the beneficiary.

a Identifying information — Enter the missing distributee’s name, date of birth, and Social Security number.

b Last known address — Enter the missing distributee’slast known address.

c Account information

(1) Enter the account number provided by the financial institution where the account balance was 

transferred that relates to the missing distributee reported in item 3a.

(2) Enterthe amount transferred to the financial institution.

If thisis an amended filing, complete item 4. Otherwise, leave this item blank.

5 The form version of Schedule A has room to report only two participants.
Instructionsfor Schedule A (Individual Information - Notifying Plans)

Form MP-200 instructions Page 13

4 Amended filing code — Enter the applicable code for each reported individual.

Code Description

A This individual was previously reported; none of the information related to this 

distributee has changed since the most recently submitted filing.

B Thisindividual was previously reported;some or all of the information related to 

this distributee has changed since the most recently submitted filing.

C Thisindividual was not previously reported.
Instructionsfor Schedule B (Individual Information - Transferring Plans)

Form MP-200 instructions Page 14

Transferring Plans must complete this schedule to report information about missing distributees 

whose defined contribution accounts are being transferred to PBGC. Plans choosing this approach 

must transfer the accounts for all of their missing distributees.

If you are:

• Using a spreadsheet to report Schedule B information, complete item 1 of Schedule B, enter

“See attached” in item 2a (the space provided for the name of the missing distributee) and leave 

the rest of the Schedule B blank.

• Entering information into the pdf-fillable form version of Schedule B and need to report 

information for more than one individual, click the button labeled “Add another Schedule B.” 6

• Entering information on a hard copy of the “form version” of Schedule B by hand:

‒ Print all information in uppercase, and

‒ If you need to report information for more than one individual, use additional Schedules B,

number each one consecutively and report the total number of Schedules B in the space 

provided at the top of the form. For example, if three Schedules B are needed, the top of 

the first schedule should show: “This Schedule B is # 1 of 3.”

Unless the instructions below indicate that an item may be omitted, all of the following information 

must be reported. (See exception re: abandoned plans in the Overview section).

Part I — Plan Information

1 Plan sponsor information — Enter the information reported in items 1a - 1c of Form MP-200.

PartII — Individual Information

2 Missing distributee information

a - d Enter the name, date of birth, Social Security Number and last known address of each missing 

distributee for whom an account is being transferred to PBGC. If the participant is deceased 

(i.e., if the missing distributee is a beneficiary), the information reported should relate to the 

beneficiary.

e Other name(s) ever used — If you are aware of other names this missing distributee has used, 

enter that information here. This item may be left blank.

f Type of missing distributee — If the missing distributee is the plan participant, check the 

“Participant” box. Otherwise, check the “Beneficiary” box. Note that a separate attachment is 

required if the answer is “Beneficiary” (see below).

Required attachment for Missing Distributees who are Beneficiaries ––The following 

information must be attached to the Schedule B if a missing distributee is a beneficiary:

• Identifying information about the plan and missing distributee (e.g., information reported in 

items 1a – c and 2a – d, including the applicable Schedule B number).

• Explanation of why this individual is entitled to benefits (e.g., surviving spouse, alternate 

payee, other named beneficiary) and the name and Social Security Number of the relevant

participant (i.e., the individual who earned the benefits). If the relevant participant is 

6 The form version of Schedule B has room to report only one participant.
Instructionsfor Schedule B (Individual Information - Transferring Plans)

Form MP-200 instructions Page 15

deceased, include the date of death.

• Any relevant documents(e.g., a copy of aQDRO, a beneficiary election form).

In addition, if any portion of the transfer amount is a Non-Qualified Roth Transfer (see item 4b), 

the following information must be included in the attachment:

• Participant’s date of birth, if alive.

• Whether the participant was disabled (if applicable).

Part III — Transfer Amount (enter amounts in dollars and cents)

With respect to the individual reported in item 2a, enter account balance information as of the Benefit 

Transfer Date. If a PBGC administrative fee is owed on behalf of this individual (i.e., if the amount 

being transferred exceeds $250), and the plan chooses to deduct the fee from the individual’s 

account, enter amounts net of the fee.

Note re: Uncashed checks - If this individual is considered a missing distributee because they did not 

cash a distribution check (see Who Counts as Missing on page 2) the total account balance must be 

reported, even if the uncashed check was for a lesser amount (i.e., because of tax withholding).

7

3 Portion attributable to pre-tax contributions (employer or employee). Report the total balance. No 

breakdown is needed.

If any portion of the account balance is attributable to post-tax contributions, complete item 4. 

Otherwise, skip to item 5.

4 Portion attributable to post-tax contributions.

Enter the portion of the account attributable to post-tax contributions as follows:

4a Portion that constitutes a Qualified Roth Transfer— Report only the total amount. No 

breakdown is needed.

4b Portion that constitutes a Non-qualified Roth Transfer— Report the total amount and 

provide a breakdown between contributions and investment earnings. In addition, be sure 

to report the date the first Roth contribution was made in item 7 (see below).

4c Portion that is attributable to post-tax contributions other than Roth — Report the total 

amount and provide a breakdown between contributions and investment earnings. 

In addition, provide a description of what this amount represents and attach a copy of any 

plan provision related to this amount. If the same plan provision relates to more than one 

individual, it is sufficient to attach only one copy. 

5 Total – Enter the total transfer amount.

7 In some situations, such as where there is a qualified termination administrator (QTA) of an abandoned DC plan (as 

defined under Department of Labor regulations at 29 CFR § 2578.1), it may not be practical to reflect the total value of 

the benefit in the amount transferred, and if so, it would be permissible for a filer to transfer to PBGC the net amount of 

the uncashed check. Filers in this situation should contact PBGC before submitting the filing.
Instructionsfor Schedule B (Individual Information - Transferring Plans)

Form MP-200 instructions Page 16

6 Check the applicable box to indicate whether any portion of the missing distributees benefit is 

attributable to non-U.S.-source income. Note that a separate attachment is required if the answer 

is “Yes” (see below).

There are different taxation and withholding rules for a distribution depending on whether the 

payment is U.S.-source or non-U.S.-source income. For more information about determining the 

source of pension payments, see Source of Income, Pension payments, in IRS Publication 515, 

Withholding of Tax on Nonresident Aliens and Foreign Entities.

Required attachment where a portion of the benefit is treated as non-US-source income – The 

following information must be attached to the Schedule:

• Identify what portion of the distributee’s benefit istreated as U.S.-source income.

• Identify what portion of the distributee’s benefit is treated as non-U.S.-source income.

• If the portion of the benefit treated as U.S.-source income is very low or zero percent, explain

why and provide additional information, such as:

o The situs of the trust if it is not in the United States.

o Any other information that would help explain why all or most of the benefit istreated

as non-U.S.-source income.

o Any information that would provide another reason why all or most of the benefit is

non-taxable. For example, If the distributee is eligible for treaty benefits with respect 

to the distribution, the applicable provision in the income tax treaty or related 

agreement under which those benefits are claimed. (This includes a copy of a valid

form W-8 BEN, Certificate of Status of Beneficial Owner for United States Tax 

Withholding and Reporting, if available.)

Part IV — Miscellaneous Information

7 If the transfer amount includes a non-qualified Roth transfer, enter the date the first Roth 

contribution was made. Otherwise, leave this item blank.

Ifthe missing distributee isthe plan participant(i.e., “Participant” is checked in item 2f), complete item 8.

Otherwise,skip to item 9.

8 Beneficiary information

a If the plan has a valid beneficiary designation form on file for this missing distributee, check the 

“Yes” box and attach a copy of the form. If the Plan does not have a valid beneficiary 

designation form on file, check the “No” box.

A beneficiary designation form is considered valid for this purpose if it:

• Includes the participant’s signature, and

• In the case of a married participant who designated someone other than a spouse, 

includes the spouse’s signed consent form witnessed by a notary.

If item 8a is “yes,” complete items 8b-d Otherwise, skip to item 9.

b-d Enter the applicable information about the beneficiary. If the beneficiary is not an individual 

(e.g., a trust), leave the Social Security Number item blank.
Instructionsfor Schedule B (Individual Information - Transferring Plans)

Form MP-200 instructions Page 17

If thisis an amended filing, complete item 9.

9 Amended filing code — Enter whichever of the following codes best applies with respect to the 

individual to whom this Schedule B relates.

Code Description

A This individual was previously reported; none of the information related to this 

distributee has changed since the most recently submitted filing.

B This individual was previously reported; some or all of the information related 

to this distributee has changed since the most recently submitted filing.

C Thisindividual was not previously reported.
Appendix 1 — Defined Terms

Form MP-200 instructions Page 18

The definitions shown below apply for purposes of these DC plan filing instructions for PBGC’s Missing 

Participants Program. These terms may have different meanings for other purposes. In general, the 

terms below are shown in capital letters throughout the instructions.

Beneficiary generally means a person designated by a DC plan participant, or by the DC plan's terms, 

to receive some or all of the participant's pension benefits upon the participant's death or some other 

event. An Alternate payee under a Qualified Domestic Relations Order also is considered a beneficiary. 

In some cases, a Beneficiary might be a trust or organization rather than an individual.

Benefit Transfer Date means the date the plan sends to PBGC the account balance available for 

distribution and the administrative fee, if applicable, with respect to missing distributees for whom the 

obligation to pay benefits is being transferred to PBGC.

Diligent Search means the process provided in 29 CFR § 4050.204 for attempting to locate distributees. 

See Appendix 2 for a summary of that process.

Distributee means a participant or beneficiary entitled to a distribution under the plan pursuant to the 

close-out of the plan.

Missing Participants Filing means, Form MP-200 and the applicable Schedule and attachments.

Non-Qualified Roth Transfer means an account transferred to PBGC from a designated Roth account in 

the transferring plan, which would not have been a qualified distribution (as defined in section 

402A(d)(2) of the Code) if it had been paid to a distributee. See “Qualified Roth Transfer” below.

Notifying Plan means a plan that elects to notify PBGC of the disposition of the benefits of one or more 

distributees who are missing upon close-out of the plan.

Participant means a person who earned a benefit under a DC plan.

PBGC meansthe Pension Benefit Guaranty Corporation.

Qualified Roth Transfer means an account transferred to PBGC from a designated Roth account in the 

transferring plan, which would have been a qualified distribution (as defined in section 402A(d)(2) of 

the Code) if it had been paid to a distributee.

Under section 402A(d)(2), a qualified distribution is generally a distribution that is made after a 5-

taxable-year period of participation and is either:

• Made on or after the date the participant attains age 591⁄2.

• Made after the participant’s death, or

• Attributable to the participant being disabled.

If a distribution is made to a participant’s alternate payee or beneficiary, then the participant’s age, 

death or disability is used to determine whether the distribution is qualified.

QDRO means a qualified domestic relations order as defined in section 206(d)(3) of ERISA and section 

414(p) of the Code.

Transferring Plan means a plan that elects to transfer accounts of all distributees who are missing upon 

close-out of the plan.
Appendix 1 — Defined Terms

Form MP-200 instructions Page 19

Unlocatable with respect to a missing distributee means that the plan does not know with reasonable 

certainty the distributee’s location upon close out of the plan (e.g., a notice from the plan is returned

as undeliverable). Note that there is a requirement to do a Diligent Search in an effort to find these

participants before reporting them as missing.

Unresponsive with respect to a missing distributee means that when the plan closes out the distributee 

either—

• Failed to submit the necessary paperwork providing instructions about how the paymentshould 

be made (e.g., by check or as a direct rollover to an IRA), or

• Did not accept a lump sum payment (e.g., by not timely cashing a check). 

See “Who Counts as Missing” in the “Overview” section for more information. 

We or “us” refers to the Pension Benefit Guaranty Corporation.

You or “your” refersto the Plan Administrator or Qualified Termination Administrator of an abandoned 

plan.
Appendix 2 — Diligent Search Requirement

Form MP-200 instructions Page 20

When a Diligent Search is (or is not) required

You must conduct a Diligent Search in an attempt to find Unlocatable distributees before reporting 

them as missing on close out of the plan. For example, if a notice about the plan termination is

returned as undeliverable, you must do a Diligent Search in an attempt to find a current address. If the

distributee is not located as a result of the Diligent Search, no further searching is required; the 

distributee may be reported as missing.

You do not have to do a Diligent Search with respect to distributees considered missing solely because 

they are Unresponsive. For example, if you have a valid address for a distributee but the distributee 

fails to return the necessary paperwork to facilitate the distribution of their account balance, there is 

no need to do a Diligent Search.

Timing of Diligent Search

A search for a missing distributee must be made no more than nine months before the Missing

Participants Filing is submitted.

What a Diligent Search entails

For purposes of PBGC’s Missing Participants Program for DC plans, a Diligent Search is one that 

satisfies regulations and other applicable guidance issued by the Department of Labor under section 

404 of ERISA.
Appendix 3 — Common Filing Errors

Form MP-200 instructions Page 21

Deceased Participants/Missing Beneficiaries

Background

As explained in the Overview section, we use the term “missing distributee” when referring to anyone 

covered by the program (i.e., a participant or a beneficiary). Thus, if the participant is deceased at the 

time the plan terminates, the missing distributee is the individual (or entity) entitled to that 

participant’s account (i.e., the beneficiary) and that beneficiary’s identifying information (e.g., name, 

Social Security number) is reported on Schedule A or B, whichever is applicable.

In addition, when the missing distributee is a beneficiary, Transferring Plans are required to submit 

additional information in an attachment (e.g., information about the deceased participant). See 

instructions for Schedule B, line 2f.

Common filing errors

In situations where the missing distributee is a beneficiary, some filers:

• Fail to include the required attachment, and/or

• Mistakenly report the participant’s identifying information.

Be sure to report the beneficiary’s identifying information on Schedule A or B, whichever is 

applicable. If you know the participant is deceased, but are unsure who the beneficiary is, enter “see 

attachment” in the space provided and include, on the required attachment, any information you 

think might be helpful in locating the beneficiary. Similarly, if there are multiple beneficiaries 

attached to the same account, enter “see attachment” in the space provided and provide the 

information in the attachment. 

Roth Accounts

Background

Benefits attributable to Roth contributions are subject to different taxation rules than other benefits 

and the rules are somewhat complicated. For example, if a participant with a Roth account receives a 

distribution less than five years before the first Roth contribution was made, the investment earnings 

on all Roth contributions are subject to taxation. The same is true if a participant is not yet age 591⁄2. 

To ensure PBGC receives the information needed to ensure IRS reporting and tax withholding are 

done properly, the “Transfer Amount” section of Schedule B has been designed such that the filer can 

provide the necessary breakdowns. More specifically, if some, or all, of a transferred account is 

attributable to Roth contributions, it must be identified as either a:

• “Qualified Roth Transfer”, which means the investment earnings are exempt from taxation, or 

• “Non-qualified Roth Transfer”, which means the investment earnings are not yet exempt from 

taxation, but depending on when the participant is located, might be exempt from taxation by the 

time it is distributed.

For more information about these terms, see definitions in Appendix 1.
Appendix 3 — Common Filing Errors

Form MP-200 instructions Page 22

Common filing errors

PBGC has received several filings where Non-qualified Roth Transfers have been reported as Qualified 

or vice versa. In some cases, this is easy to spot (e.g., a missing participant who, according to the 

reported date of birth, is much younger than 591⁄2 where amounts are reported in the space for 

“Qualified Roth Transfers”). 

It is essential for transfer amounts to be identified correctly. 

We suggest anyone transferring benefits attributable to Roth contributions schedule a pre-filing 

consultation with PBGC before preparing the filing. See What’s New section for more information. 

Uncashed checks issued in conjunction with the plan’s termination

Background

As explained in the Overview section and in the line-by-line instructions for Schedule B, Part III, one of 

the ways a participant is considered missing is if, when the plan closes out, the participant did not 

accept a lump sum payment, such as a check issued by the plan in conjunction with the plan’s 

termination. In situations where the plan is transferring the amount owed to a participant who is 

considered missing because they did not cash a distribution check that was sent in conjunction with 

the plan termination, the transfer amount must reflect the total value of the benefit without any 

reduction for tax withholding.

Common filing error

PBGC has received several filings where the amount transferred is net of tax withholding. 

PBGC appreciates that, in some situations, such as where there is a qualified termination 

administrator (QTA) of an abandoned DC plan, it may not be practical to reflect the total value of the 

benefit in the amount transferred, and if so, it might be permissible for a QTA to transfer to PBGC the 

net amount of the uncashed check. If you are in this situation, contact PBGC before submitting the 

filing. Also, if you are a QTA, be sure to check that box in the certification section.

Post-tax contributions other than Roth (Schedule B, line 4c)

Background

As noted in the instructions for Schedule B, Line 4, transfer amounts attributable to post-tax 

contributions, including investment earnings on those contributions, usually relate to Roth 

contributions. However, some plans permit post-tax contributions other than Roth, or did so in the 

past. Because the taxation rules are different for these amounts, it is imperative that amounts 

attributable to post-tax contributions be classified correctly (i.e., Roth or Other). Amounts 

attributable to Roth contributions are reported on line 4a or 4b (depending on whether the transfer 

is qualified or not) and amounts attributable to other post-tax contributions are reported on line 4c.
Appendix 3 — Common Filing Errors

Form MP-200 instructions Page 23

Common filing error

Because it is no longer common for a plan to permit post-tax contributions other than Roth, PBGC has 

been reaching out to all filers who report amounts in the space provided for the portion of the 

account attributable to such contributions to confirm that such amounts were classified correctly, so 

that such amounts can be taxed correctly when distributed. In almost all of those situations, it 

turned out that those amounts were not, in fact, attributable to post-tax contributions other than 

Roth. In most of those cases, the amount reported (and transferred) represented the face value of 

an uncashed distribution check (i.e., the amount net of amounts withheld for taxes). As noted above, 

in such cases, the gross amount is to be transferred. Please see the section on “Unaccepted Lump 

Sums” above in these instructions and contact PBGC before submitting a filing that reports the face 

value of an uncashed distribution check. In addition, such amounts should be reported in the 

appropriate place (i.e., line 3 or 4a, 4b, or 4c, whichever is applicable).

Because PBGC has received so many filings where amounts have erroneously been reported in 

Schedule B, Line 4c, the filing instructions now require filers reporting amounts in that line to provide, 

in an attachment, information about the nature of those contributions.
Appendix 4 — Paperwork Reduction Act Notice

Form MP-200 instructions Page 24

We need this information to facilitate the payment of benefits or the sharing of information as 

required under section 4050 of ERISA and 29 CFR part 4050. You are required to give us this

information. Confidentiality is that provided by the Privacy Act and the Freedom of Information Act.

OMB has approved this collection of information under control number 1212-0069. An agency may 

not conduct orsponsor, and a person is not required to respond to, a collection of information unless 

it displays a currently valid OMB control number.

PBGC estimates that preparation and submission of a filing will on average take under an hour of inhouse plan time and $1,443 in contractor costs. These are estimates; the actual time and cost will vary 

depending on the circumstances of a given plan.

If you have comments concerning the accuracy of these burden estimates, or suggestions for making 

the forms or the filing process simpler, please send your comments to Pension Benefit Guaranty 

Corporation, Office of the General Counsel, Regulatory Affairs Division, 445 12th Street SW 

Washington, DC 20024-2101.