Missing Participant Whose SS# is Unknown

[mming]

A qualified plan is terminating and one of the participants who terminated many years ago cannot be located - her last known address is not valid and her SS# is not known. The amount due to the participant cannot be rolled over to a safe harbor IRA since a SS# is needed to do so, and presumably the SSA locator service cannot be used. The amount due is about $1,400, so hiring a private service to locate the individual may not be prudent since that would probably consume the majority of the benefit due, and it would seem very unlikely she would be found given the lack of available info. Are there any better options other than 1) escheating the amount to the state, or 2) paying it all out as 100% withholding? Are there any financial institutions that can set up an IRA without a SS#?

[MoJo]

A qualified plan is terminating and one of the participants who terminated many years ago cannot be located - her last known address is not valid and her SS# is not known. The amount due to the participant cannot be rolled over to a safe harbor IRA since a SS# is needed to do so, and presumably the SSA locator service cannot be used. The amount due is about $1,400, so hiring a private service to locate the individual may not be prudent since that would probably consume the majority of the benefit due, and it would seem very unlikely she would be found given the lack of available info. Are there any better options other than 1) escheating the amount to the state, or 2) paying it all out as 100% withholding? Are there any financial institutions that can set up an IRA without a SS#?

Berwin or intellius.com are reasonably priced search services that may not need the SS# (although it helps). Check with Inspira about a rollover (and they also do searches). Not sure about the cost.

[mbozek]

A qualified plan is terminating and one of the participants who terminated many years ago cannot be located - her last known address is not valid and her SS# is not known. The amount due to the participant cannot be rolled over to a safe harbor IRA since a SS# is needed to do so, and presumably the SSA locator service cannot be used. The amount due is about $1,400, so hiring a private service to locate the individual may not be prudent since that would probably consume the majority of the benefit due, and it would seem very unlikely she would be found given the lack of available info. Are there any better options other than 1) escheating the amount to the state, or 2) paying it all out as 100% withholding? Are there any financial institutions that can set up an IRA without a SS#?

Cant use 100% withholding. Many states will not accept transfers from ERISA plans because of preemption concerns.

Does plan have a provision that permits forfeiture of benefits if participant cannot be located?