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Terminating a 403(b) with individual custodial accounts

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I've been reading about the issues relating to terminating a non-ERISA 403(b) with individual custodial accounts (little or no ER involvement). The plan we're working with now has only a handful of current employees who are willing to liquidate their accounts and roll the assets over to IRAs. So far, so good. However, we were just told that there are a couple of former employees who left several years ago. Nobody knows what happened to their accounts. I'm afraid that I now have to tell the Director that the plan can't be terminated unless we can track down those former employees. Am I right about that?

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