401(k) Plan - Uncashed Checks and Missing Participants

[rocknrolls2]

Company maintains a 401(k) plan for its employees. One of the provisions states that if the plan administrator is unable to have a check to a participants or beneficiary cashed, after the use of reasonable diligence in attempting to locate the person, then the check amount is forfeitred until or if a claim is made for the amount, in which case it will be fully restored without earnings. Similarly, if a benefit is required to be paid by the plan, but cannot due to inability to locate the participant or beneficiary, then the account balance is forfeited until a claim is made, in which case it will be restored. Based on IRS regulations, I am comfortable with this approach.

The question that arises is how is the Schedule SSA reporting handled? If the participant terminates employment and does not take a distribution, then the participant's account balance is reported on the Schedule SSA. If there is an uncashed check or an account balance that is forfeited because the participant could not be located, are you now required to enter Code B or C in line 4 box A? What if the check remains unclaimed or the account balance remains unclaimed? Do you enter Code D in line 4, Box A?

[WDIK]

Since the account balance is required to be restored if a future claim is made, it appears to me that the participant is still entitled to those benefits and Code D would not apply.

Since the account balance is required to be restored if a future claim is made, it appears to me that the previously reported information has not been modified and Code B would not apply.

Since this participant was not previously reported under another plan, it appears to me that Code C would not apply.

I do not think that any additional reporting on Schedule SSA should be done.