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Sounds as though you need a new locator to find the old locator service!

My QDRO Alternate Payee clients will move to a new home, or remarry and take a new spouse's surname, and they will notify the Social Security Administrations, Motor Vehicle Administration, their Post Office, credit card companies, banks, everyone they know EXCEPT the Plan Administrator of the defined benefit Plan from which they are hoping to someday receive a share of their former spouse's retirement and survivor annuity benefit. I have for years included in all of my QDROs the current addresses of both parties, their personal phone numbers, and their personal email addresses. My motive is to give the Plan Administrators a second and third shot at finding the parties at significant events such as retirement and death. You administrator folks should insist upon it. David

We also use a generic letter that does not disclose the reason for the inquiry, and simply requests that they contact us. If they do so, we use multiple identifiers to confirm. We also use PBI.

I think we use PBI as well.

The search services I mentioned does have a level of service that does send a letter to them to confirm it is good by letting them know they are being looked for by a plan. If an address is found we often times suggest the our client reach out to them to get them paid as it is rarely an employee who is lost. They will have the best ability to detect if something is amiss as they have background data on the person. However, at some point once you think you found someone you get them forms to sign. If a person signs for someone they aren't they did the crime. I get a fiduciary has some responsibility but I have never seen this blow back on a client who has used a reasonable process. The fiduciary obligation don't require them to be mind readers after all.

@Peter Gulia your question highlights what many do not consider when hiring a search firm or launching a search for good addresses and for missing participants. A participant with a bad address or who is missing is still a participant with an interest in the plan. Plan fiduciaries are charged with acting in the interests of participants, and plan fiduciaries should have an understanding about the steps to be taken once an address or a missing participant is "found". I use quotes because, while the initial search results often are successful, a significant percentage of the initial search results are only the beginning of what can be an involved and tedious process. Notably, most search firms offer different levels of search services. The basic search scans publicly accessible databases. The next level of search scans databases where the search firm has privileges to access the data (and commonly the search must pass a level of scrutiny that they have adequate security in place for managing the search results and have made representations about how the search firm will use the data). The results are communicated to the plan sponsor or a plan service provider. Many of the search firms offer a service where they will send a generic letter to the individual's address that the search has found and provide information in that letter about who the individual should contact. This contact may be someone at the client, or possibly someone at a service provider for the plan (for a fee). If the individual initiates contact, the client or service provider should have sufficient information about the participant to be able to validate the contact. The plan fiduciaries should be mindful that the search firms are service providers to the plan. If the plan contracts with the search firm directly, then the plan should have service agreements in place that cover the scope of services and fees. Given that the expenses of resolving a bad address or finding a missing participant may be disproportionately greater than the value of the participant's benefit of the plan, some plan fiduciaries set parameters for adjusting the level of search services for different groups of participants. That being said, what happens next when these initial efforts do not reestablish contact with a participant and there is reason to continue to pursue the effort, often leads to much more complicated scenarios. For example, the search may reveal that the participant: is deceased and may or may not have designated beneficiaries, is incarcerated, may have legally changed names, has moved outside of the US, has been declared missing or deceased, or many other situations that are not limited by any stretch of the imagination. The larger the plan, the greater the likelihood of these circumstances coming up. These are topics that can take us far beyond the original post.

I really like PBI locator services. The thing I like about them is they will give you a letter regarding what they did to find this person. So if someone like the DOL asks about due diligence you produce this letter.

I have used penchecks and Employee Locator https://employeelocator.com/ Both were inexpensive, easy to use, and provided quick results. I found the information provided by Employee Locator more through and complete as they provided possible phone numbers and e-mail addresses as well as past address of the participant in addition to a current address. But it's still sometimes hit or miss if the addresses either place provide finds the actual participant. The last participant we searched for wasn't at the address that either company provided. I get no referral fee from either, just giving you my feedback.

@RatherBeGolfing raises some of the operational issues that the client must understand fully and be able to set the expectations of participants on how the SDBAs will work inside the plan. Ascensus and Schwab each have a lot of experience with SDBAs inside plans and they also have links to share data electronically. While that sounds wonderful, there remain complications for recordkeeping the plan. One of the bigger challenges stems from allowing multiple contribution sources to be invested in the SDBAs. There is potential for a contribution source to be pre-tax or Roth. Each source may have differing in-service withdrawal provisions, differing vesting, differing loan availability and other variances in features. When recordkeeping a plan that uses a menu of mutual funds, each transaction be it a contribution, distribution, exchange, dividend, new loan, loan repayment... can be labeled with a plan account (deferral, NEC, match, rollover, ...) and the mutual fund in which the transaction occurs. When there is what @RatherBeGolfing termed "shadow posting", the recordkeeping treats the SDBA as if it is a single investment. The identity of the mutual fund is lost. When recordkeeping with a menu of mutual funds, the price per share of each fund is known after market close and before market open. Depending upon the frequency in which the market value of the SDBA is sent to the recordkeeping system, the "price" of the SDBA investment may not be known within the menu of mutual fund's time frame. The plan should not allow participants to grant trading privileges to brokers or financial advisers that are not approved by the Plan Sponsor. Allowing participants to choose advisers of their choice is a recipe for chaos, and could lead to questions over who is controlling the investment of plan assets. The plan audit should not be dramatically impacted by the SDBAs. Schwab and the trustee both should be issuing reports that include all of the detail needed by an auditor with experience auditing SDBAs. The Plan Sponsor should vet the auditor to confirm that the auditor does have this experience of the cost of the audit could skyrocket. I share @RatherBeGolfing's concern about who is providing compliance services although my concern is driven more by the competence of who is providing the services rather than by having SDBAs as an investment option. Note that the proposed arrangement for the SDBAs is relatively simple compared to some of the plans I have recordkept. For example, this arrangement: uses only one brokerage firm and participants do not get to open an account at the brokerage of their choice' restricts investments to mutual funds and participants cannot invest in stocks, bonds, CDs, ETFs, ETNs, gold, annuities...; does not allow trading in options; does not allow investing in assets that do not have a readily determinable value such as real estate, LPs, private placements, art... The advice to the client is to know the details, prepare written policy (including dos and don'ts), and communicate clearly to participants. Some plans go so far as to have a participant sign a representation that the participant understands the policy.