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Recoupment of Uncashed Checks

As reported by law firm Morgan Lewis, the DOL has issued letters encouraging retirement plan sponsors to recoup amounts represented by uncashed participant benefit checks held by former recordkeepers or paying agents. It is thought that the recent DOL investigations of retirement plan recordkeepers may serve as impetus for this action. More specifically, the letters request that plan fiduciaries provide documentation proving restoration of uncashed check amounts, inclusive of lost earnings, “appropriately” allocated to accounts of affected participants and beneficiaries.; August 16, 2021.