No Social Security Numbers for lost participants

[Santo Gold]

There are several terminated participants who have account balances in a recent takeover plan that we are TPAs for. For 2 of these terminees, they left years ago, and the employer has no information on them, not even their Social Security Numbers. Any advice on how to go about finding someone without SS #'s?

Another concern is that even if we "find" these lost participants, how can we identify that they are who they are? They can say "Yes, I am John Doe, here is my SS#" but since we can't confirm that the SS# is correct, doesn't that create a potential problem for the Plan Administrator. Paying out to someone other than a participant or beneficiary?

[J Simmons]

Does the employer not have copies of the Forms W-2 that it issued to those former employees or Forms W-4 those employees filled out? Those are a source of SSNs.

If the employer cannot produce those, and you have individuals coming forward, ask each person that might claim to be a former employee to identify the position they held with the employer, date of hire, date of termination, and then pass the info by the employer and have the employer confirm, deny.

[Santo Gold]

After some prodding and more digging, SS#'s did turn up for all terminated participants. Now we just have to locate these people.

J. Simmons: I think what you suggested is reasonable. Its an interesting problem though, that if there are no records (other than their names) of their employment, and if no one currently at the company worked with the terminees, it would be difficult to be 100% certain if the lost participant is who he says he is.

Thanks for replying.

[david rigby]

Report them on a Schedule SSA (don't worry about whether they have already been reported).

[katieinny]

We've had more than one situation where it's impossible to find missing participants because the social security numbers were bogus, which is just as bad as having no SS# at all. Do you open an IRA with an SS# that you know is wrong?