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George also caused a bomb scare because he was trying to nap at work, just sayin...

PensionPrisoner, if you are trying to do a direct rollover by placing a check in the possession of the distributee participant, Treas. reg. 1.401(a)(31)-1, Q&A's -3 and -4 provide guidance regarding to whom the check should be made out. The last sentence of Q&A-4 specifically provides for the use of "FBO John Smith" in some circumstances involving a rollover to a qualified plan, but as you will see if you read it, a different way of completing the payee is suggested for IRAs. I think the IRA custodian you are dealing with is probably trying to closely follow this reg, even though it is probably not necessary to do so. But doesn't hurt.

It's common but I don't think it is required. I'd push back and ask why it's so important to take it off... Personally I think it's a good idea to have "IRA FBO..." or similar language so the participant can't deposit it into an after-tax account.

"Long story short, the actuarial was unable to accurately anticipate the aggressive nature of our client's investing and currently has a nearly $1mm overfunding situation." This is my favorite line. Your client didn't listen to the actuary and it's the actuary's fault.