Terminated Plan & NTIP

[Guest kjk]

Does anyone have any suggestion regarding the following: a 401(k) plan was terminated this past summer. The plan sponsor has been making distributions of all account balances (I know, I know, it is generally recommended that you get a determination letter before distributing plan assets, but we are where we are) and is only now completing the Form 5310 application for terminating plan. The problem is, the plan sponsor already knows that some former employees are "missing participants;" that is, the plan sponsor does not have a currrent address on file for these individuals and has already submitted materials to the Social Security Administration's letter forwarding program so that distribution of their account can be made. So, the question is, how do we send the Notice to Interested Parties to these people? This is a strange situtation, because normally, I would advise the plan sponsor to send the NTIP to the last known address, but if the plan sponsor already knows the last known address is incorrect . . . what do we do? Thanks for any advice.