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My take on "life of the marriage" awards is to be completely upfront about the difficulty in obtaining balance records, particularly when the dates are far back in time and/or not aligned to typical reporting periods (quarterly/annually). When I get one to review where I know that my organization lacks the records, my typical approach is to inform the sponsor that I can only go back to a certain date (usually the date they engaged services) and any necessary records prior to that will need to be provided by the sponsor or by the participant. I've only ever seen such records produced once or twice. This approach is almost always effective in making the parties stop to think about which matters more to them - the precision in the amount awarded or the speed at which the award amount can be transferred to the alternate payee's account. Once they can see that trying to obtain records for a balance on 9/18/86 is likely to be a drawn-out and perhaps fruitless search, attitudes start to shift. Much of the time, at least one of the parties is willing to take a financial hit simply to have the issue settled quickly.

The rest of the post seems to indicate you have a self-directed plan. Anyway, in these situations, we just leave the forfeitures in the old account (of the term'd participant) and close it completely the following year.

I agree with your approach to fit the circumstances. Even in my dream world the plan cannot bring forward earnings from early dates, such as "50% of the balance as of the January 17, 1998 divorce, with earnings on the AP's share until distribution." The parties to the order have to figure out some formula or number for the earnings up to some viable date in the present administration system. There is no legal requirement for the plan to perform that function, so 414(p)(3)(A) would apply. But there is that nasty records requirement for balances. The reason my clients can do it is becuase we have been advising them about what needs to be done when record keeping changes.

For real. The point you make is a good one, but involves different issues and a different set of policies. And I believe that a plan has an obligation to keep historical balances no matter how many changes in record providers, not that they do it properly. I do not think they have to keep daily balances, which gets into policies about using reasonable valuation dates and conventions for identifying the appropriate one to the extent the order does not specify (the valuation date that is nearest the desired date, immediately preceeding, or immediately following?). Most of my clients can handle January 17, 1998 within legally acceptable tolerances (the answer is December 31, 1997). I am living the dream.