Identity Management Services Organization, LLC 401(k) plan: what happened, and where the money went

Identity Management Services Organization, LLC's 401(k) plan filed a final Form 5500 for 2023, and $5,465,356 was paid out to participants. The plan's recordkeeper was Gwla. If you had a balance, it was paid out to you or moved into a rollover or safe-harbor IRA in your name — it isn't lost.

No. When a plan terminates, federal law requires every balance to be paid out or moved to an account in the participant’s name — it cannot simply be kept. The most common reason people cannot find it is that they did not respond to the termination notices and the balance was moved to a safe-harbor IRA they have never looked at. The steps below are how to track it down.

When an employer ends a retirement plan — because the company closed, was acquired, went through bankruptcy, or simply wound the plan down — every participant becomes 100% vested and the plan must pay out all balances. Participants receive notices asking where to send their money: roll it to an IRA, roll it to a new employer’s plan, or take a cash distribution.

Balances of participants who don’t respond are typically moved automatically into a "safe harbor" IRA opened in the participant’s name at a custodian the plan chose. These accounts are usually invested in cash or money-market funds and charge maintenance fees — money parked there often grows slowly or shrinks. If you ignored the letters, your money may be sitting in an account you’ve never looked at. You can search for it via the plan’s termination notices, old statements, or the Department of Labor’s abandoned plan search.

Money that came out of a terminated plan can generally: (1) stay where it landed — for example in a safe-harbor IRA — though it’s worth checking the fees and how it’s invested; (2) be rolled into your current employer’s retirement plan, if that plan accepts roll-ins; (3) be rolled into an IRA you choose, which keeps it tax-deferred; or (4) be taken as cash, which is generally taxable and may carry a 10% early-withdrawal penalty before age 59½. Direct trustee-to-trustee rollovers avoid the 60-day deadline and tax withholding that apply when a check is made out to you personally. Each option has trade-offs; none is right for everyone.

1. Look for the plan’s termination notice or your last statement — it names the firm holding the money and the account it went to.

2. Contact Gwla, the plan’s recordkeeper, with the plan name and number shown on this page.

3. Search the DOL Abandoned Plan Search and the DOL Retirement Savings Lost & Found.

4. Check the National Registry of Unclaimed Retirement Benefits.

5. Check your state’s unclaimed property office — uncashed distribution checks often end up there.

6. If those come up empty, the plan sponsor’s contact details from the final filing are listed above; the company may no longer exist, but the plan administrator’s records were required to be kept.

An individual retirement account a plan is allowed to open in your name, without your involvement, to hold a balance you did not give instructions for when the plan closed. It is still your money and still tax-deferred, but these accounts are usually invested in cash or a money-market fund and charge maintenance fees, so the balance tends to sit still or shrink until you move it.