Might be possible for the TPA to find an insurance co willing to take the defined benefit amount even without a SSN or TIN. Many old terminated DB contracts never had SSN or TIN for participants -- just names, id numbers and addresses. The insurance cos would then solicit full information from the participant. (Making it the insurance co problem rather than the plan admininstrator's or TPA's.)
In terminating the plan presumably a broker and/or insurance company was part of the process. They should be able to help you add the missing, now found, participant to the contract that was developed to provide benefits to participants of the plan.
Agree with 2 cents. Should also include terminated vested participants who as a result of offset have nothing due to them under the defined plan assuming that there is still something due them from the defined contribution plan.
Escheat the amount to the state the participant last resided in. Include a notice to that state's property division indicating the number of benes. Send notices that this has been done to those bene's that are known. Keep a record of what was done and why; and set this method as a last resort contingency process.
Facetiously: Send the lawyer a hard copy of the Code (along with a bill for same), with a nice note that between the enclosed and the copy of the SPD previously sent should provide all the information required as to why the change can not be done.