Recovering Uncashed Benefit Checks Across International Boundaries

A large U.S.-based manufacturing company with multiple defined contribution (DC) plans and tens of thousands of participants identified a growing issue with uncashed benefit payments. Over time, required minimum distributions (RMDs) and other benefit checks had gone uncashed, creating administrative complexity and potential fiduciary exposure for the plan sponsor. Several cases involved long-standing stale checks where participants or beneficiaries had not been located despite some outreach attempts and the use of third-party search vendors.

The issue was particularly concerning in higher-dollar cases, especially since the Department of Labor expects plan sponsors to demonstrate robust, good-faith efforts to locate missing participants or beneficiaries and ensure benefits are paid.

SBA began by reviewing plan data to identify and inventory all stale checks, cross-referencing pension records for existing ACH payment instructions and spouse or relative contact information where available. This created a clear picture of both the number and dollar value of outstanding payments. Using a risk-based approach, SBA worked with the plan sponsor to prioritize cases involving larger balances, where enhanced due diligence was most critical.

SBA then executed a multi-layered search strategy that extended well beyond standard vendor tools. In addition to public records and traditional outreach methods, SBA conducted targeted research across social media platforms, historical employer records, and international employment statuses. In several cases, this work required tracing participant and beneficiary activity across multiple continents, including Europe and Asia, to identify next of kin and validate benefit entitlement. SBA also leveraged long-standing HR relationships and institutional knowledge to confirm participant status and next of kin information in cases involving deceased, terminated, and separated individuals.

SBA’s targeted outreach and enhanced due diligence produced meaningful results. In a matter of months, SBA helped the client deliver more than half of previously outstanding checks to participants and beneficiaries and continues to reunite benefits with their intended recipients at a rapid pace. One auto-reissue initiative alone reconnected 300 people with $400,000 in benefits.

In one complex case, SBA discovered that a participant with approximately $600,000 in stale checks had passed away. Through careful research, SBA located the participant’s beneficiary, who not only received the uncashed payments, but also properly claimed the participant’s full plan balance of over $2 million.

Beyond resolving legacy cases, SBA also introduced process enhancements and plan provision changes designed to slow the growth of new stale checks over time. Over a two-year period, the client’s overall rate of new outstanding checks dropped by 55%, reflecting more timely outreach and a more sustainable approach to plan operations. By resolving long-standing cases and implementing a more defensible process, the plan sponsor significantly reduced administrative burden and strengthened its fiduciary posture.