PROGRAM OPERATIONS MANUAL SYSTEMPart RM – Records MaintenanceChapter 032 – Pension Information Processing SystemSubchapter 70 – Field Office Handling of ERISA InquiriesTransmittal No. 6, 08/04/2026
Audience
Originating Component
EEM
Effective Date
Upon Receipt
Background
The updated policy reflects changes in the Document Control Number (DCN) formats and data sources, with the digit count for current and M-coded notices revised from 13 to 12 digits and the 14-digit DCN data source updated from EFAST to the IRS FIRE system. The section specifies the use of modern data processing and storage systems, such as AIRS and IRON, replacing previous references to microfilm and the Wilkes-Barre Direct Operations Center. Contact and referral information is modernized, directing inquiries to the Employee Benefits Security Administration (EBSA) with updated web and phone resources. Procedural guidance is expanded and clarified, including updated forms and verification processes; removed outdated contractor references and certain procedural notes to improve clarity and accuracy.
Summary of Changes
RM 03270.009 Handling Inquiries About SSA's ERISA Notice on Form SSA-L99-C1
Subsection B:
Changed the DCN digit count from "13 digit" to "12 digit" for current and M-coded notices.
Changed the source of data for 14-digit DCN from "EFAST input" to "IRS Filing Information Returns Electronically (FIRE) system."
Added specific data processing systems: AIRS for 12-digit DCN, IRON database for M-coded 12-digit DCN.
Removed mention of Wilkes-Barre Direct Operations Center (WBDOC) and microfilm location details.
Deleted entire paragraph describing WBDOC process and microfilming.
Deleted note about handling "M" and non-"M" notices the same.
Subsection C:
Added instructions to advise inquirers to use the DOL EBSA Retirement Savings Lost and Found Database; updated contact info including website, toll-free number with translation services, and TTY access via dialing 711
Changed references from DOL to specifically the Employee Benefits Security Administration (EBSA).
Added "General Guidance" about SSA's role in ERISA and references to POMS.
Added reference to POMS under “additional resources for inquirers” and replaced DOL contact info with EBSA contact info.
Restructured the table with detailed guidance based on DCN types.
Added instructions to refer inquirers to EBSA for additional help and resources.
Expanded explanation of DCN types with specific sources and additional information:
For “M” coded SSA 12-digit DCN: Source is paper Schedule SSA from Form 5500 (replaced by Form 8955-SSA effective 12/31/08)
For “NON-M” coded SSA 12-digit DCN: Source is paper Form 8955-SSA.
For “NON-M” coded SSA 14-digit DCN: Data received electronically from IRS FIRE system, no microfilm.
For "More Information — Plan Says NH Was Not a Participant":
Added procedure for “NON-M” coded SSA 12-digit DCN inquiries involving Form 8955-SSA verification.
Added referral to EBSA for remaining questions or concerns
For 14-digit-only coded notices, added referral to EBSA contact info in addition to plan administrator.
Updated instructions for FO technicians to prepare a written request to EOS and clarified use of local fax procedures.
Added explicit reference for 800 Number agents to follow POMS
Removed outdated instruction to prepare a memorandum to OCO and request a microfilm copy of the Schedule SS
RM 03270.015 Exhibit 1- SSA-L99-C1, Notice of Potential Private Pension Benefits
Replaced the outdated SSA-L99-C1 exhibit with the current version.
RM 03270.016 Exhibit 2 - SSA-L99-C1, Notice of Potential Private Pension Benefits - Non-M Notice
This section archived.
RM 03270.017 Exhibit 3 — Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits
RM 03270.020 Exhibit 2 — Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits
CITATIONS:
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.
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:
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).
14-Digit DCN
Data Source: Information received electronically from the IRS Filing Information Returns Electronically (FIRE) system.
Notices are generated with a 14-digit SSA DCN.
These notices are fully systems generated and do not include stored images.
M Followed by 12-Digit DCN
Data Source: Information from paper forms (previously known as Form 5500 Schedule SSA) received prior to 2008.
These forms were microfilmed.
Information is saved to the Image Retrieval Online (IRON) database.
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
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.
For NON-M coded SSA 12 digit-only DCN:
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.
Additional information regarding the inquiry may be available in SSA’s AIRS application.
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.
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:
Website: https://askEBSA.dol.gov and click “Message Us”
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
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
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
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.
ERISA “M” Notice
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Exhibit 1, SSA-L99-C1, Notice of Potential Private Pension Benefits - (Back)