Effective Dates: 08/04/2026 - Present Previous | Next

TN 6 (08-26)

RM 03270.009 Handling Inquiries About SSA's ERISA Notice on Form SSA-L99-C1

CITATIONS:

Social Security Act, as amended, Section 1131 (42 U.S.C. 1320b-1)

A. Introduction

Most field office (FO) or 800 Number inquiries occur after the inquirer receives Form SSA-L99-C1, “Notice of Potential Private Pension Benefits” (Exhibit 1, RM 03270.015), from Central Office. This notice is sent after a written request is made or claim for title II benefits or hospital insurance benefits is filed.

B. L-99 Notices effective after 06/10/04

There will be three different Document Control Numbers (DCNs) on the ERISA SSA-L99-C1, Notice of Potential Private Retirement Benefit Information Notice. The DCN is located in the "For SSA Use Only" block at the bottom of the notice. The content of the notices is the same except for the DCN that defines the source of the data and how SSA processes that data.

Types of DCNs:

  1. 1. 

    12-Digit DCN

    • •

      Data Source: Information received from paper forms sent by the Internal Revenue Service (IRS) from pension plan administrators.

    • •

      Data Processing:

      • –

        Information is keyed into electronic files.

      • –

        Images are stored in the Automated Image Retrieval System (AIRS).

  2. 2. 

    14-Digit DCN

    • •

      Data Source: Information received electronically from the IRS Filing Information Returns Electronically (FIRE) system.

    • •

      Data Processing:

      • –

        Notices are generated with a 14-digit SSA DCN.

      • –

        These notices are fully systems generated and do not include stored images.

  3. 3. 

    M Followed by 12-Digit DCN

    • •

      Data Source: Information from paper forms (previously known as Form 5500 Schedule SSA) received prior to 2008.

    • •

      Data Processing:

      • –

        These forms were microfilmed.

      • –

        Information is saved to the Image Retrieval Online (IRON) database.

C. Procedure

Use the following table to respond to common inquiries about the ERISA Notice on Form SSA-L99-C1:

NATURE OF INQUIRY

ACTION

Explanation of the ERISA Notice

General Guidance:

  • •

    SSA Administers certain aspects of the ERISA. Responsibilities include processing pension plan data received from the IRS, maintaining IRS pension plan records, and mailing pension plan informational notices.

  • •

    Refer to SSA's role in ERISA as set out in this sub-chapter and in RM 03201.005. For terms used in this notice, refer to RM 03270.011.

  • •

    For general ERISA notice inquires, when there is no additional information available for pension plan fund records that were processed electronically, direct individuals to the U.S. Department of Labor's (DOL) Employee Benefits Security Administration (EBSA) Retirement Savings Lost and Found Database at https://lostandfound.dol.gov for more information about pensions and locating the plan administrator.

Responding to Inquiries Based on DCN Type

  1. 1. 

    For “M” coded SSA 12-digit DCN:

    • •

      Source of data:

      • –

        Derived from the paper Schedule SSA Form 5500 (Schedule SSA was replaced by Form 8955-SSA effective 12/31/08) we used to receive from DOL.

    • •

      How to Respond:

      • –

        To address questions regarding the data on this notice, advise that SSA will review the microfilmed data and respond in writing.

  2. 2. 

    For NON-M coded SSA 12 digit-only DCN:

    • •

      Source of data:

      • –

        Derived from the paper Form 8955-SSA Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits filed with the IRS by the pension plan.

    • •

      How to Respond:

      • –

        Additional information regarding the inquiry may be available in SSA’s AIRS application.

  3. 3. 

    For “NON-M” coded SSA 14 digit-only DCN:

    • •

      Source of Data:

      • –

        Data was received through electronic transmission from the IRS; SSA does not have other records or microfilm information.

    • •

      How to Respond:

      • –

        There is no additional information available for pension plan fund records that were processed electronically. Explain that SSA received the data through electronic transmission from IRS and that SSA does not have any other records nor is the information on microfilm.

Additional Resources for Inquires

  • •

    Inform inquirer that EBSA can assist them in understanding the ERISA notice, locating contact information for the plan administrator, and applying for retirement benefits.

  • •

    Provide contact information for EBSA advisors:

    • –

      Toll-Free Number: 866-444-3272 (translation services available).

    • –

      Tell inquirers they can watch DOL’s helpful video about these notices at https://askEBSA.dol.gov.

Information on Filing for Pension Benefits

Advise inquirer to contact the plan administrator.

Plan Name and Current Address — Address Shown on ERISA Notice is Incorrect

Explain that:

  • •

    Plan name and address shown on ERISA notice was the pension plan name and address reported to IRS for the plan year shown in the “year reported” block of the notice.

Refer the inquirer to the employer of the plan participant covered by the plan; and, if employer cannot be contacted, refer the individual to EBSA and provide inquirer with information found in RM 03270.009C under “additional resources for inquirers”.

Former Plan Name

Explain that:

  • •

    The name shown in this block is a previous name reported by an administrator of the plan and has now been updated with the current plan name and address.

NOTE: This alerts the recipient that there was a change in the plan administrator.

Why the Pension Benefit Guaranty Corporation is Shown as Plan Administrator

Explain that:

  • •

    The Pension Benefit Guaranty Corporation (PBGC) takes over administration of certain pension plans when the plan terminates to ensure that participants receive their vested benefits.

NOTE: Only “defined benefit plans” (see RM 03201.003) are insured by PBGC and thus subject to PBGC administration when the plan terminates.

Explanation of Why Pension Amount Shown on ERISA Notice Differs From Amount Determined By the Plan

Explain that:

  • •

    The amount shown on the ERISA notice was the amount reported to IRS or DOL/NCS by the plan at the end of the plan year shown on the form.

  • •

    The notice does not reflect any changes in the pension plan provisions that occurred after the plan year shown.

  • •

    In the case of PBGC-administered plans, the law limits the pension amounts that can be guaranteed by PBGC.

More Information — Plan Says Plan Participant Was Not a Participant

“M” Coded Notice

If the plan participant's SSN was correctly shown on the ERISA “M” notice:

  • •

    Field Office (FO) Technicians:

    Prepare a written request to Earnings Operations Support (EOS), following the instructions in RM 03270.005B.1.a-c. Send the request using local fax procedures to EOS, requesting verification that the pension plan name and address shown on the ERISA notice is the same as shown on the Schedule SSA.

  • •

    800 Number Agents: Follow instructions in RM 03270.005B.1.d to request verification of the plan participant's name, plan name, and address as shown on the ERISA notice.

If the SSN shown on the ERISA notice belongs to the inquirer, follow the procedures below.

14 Digit-Only Coded Notice

  • •

    If the plan participant's SSN was correctly shown on the ERISA notice, tell the inquirer that SSA does not have any additional data because their information was transmitted electronically to SSA and there is no microfilm on file. Tell the inquirer to contact the plan administrator for further explanation.

More Information — Plan Says No Benefits Are Payable
  • •

    Advise the inquirer that ERISA laws provide that pension plans provide for a full and fair review of all denied claims and the inquirer may request such a review within 60 days of the denial of the claim with the plan administrator.

  • •

    If the inquirer is a surviving spouse of the plan participant, ask if the plan participant or spouse ever waived surviving spouse's benefits or if the plan participant had cashed out their pension benefits. If so, explain that this may be the reason no surviving spouse's benefit is payable.

NOTE: ERISA laws did not require the spouse's consent to waive survivor benefits prior to 1985 (for single employer plans) or prior to 1987 (for multiple employer plans); and pension plans may “cash out” (refund to the plan participant) vested benefit amounts of $3500 or less without the participants' spouse or surviving spouse's consent.
To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/0103270009
RM 03270.009 - Handling Inquiries About SSA's ERISA Notice on Form SSA-L99-C1 - 08/04/2026
Batch run: 08/04/2026
Rev:08/04/2026