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DB termination under standard provisions. Participant could not be located and was handled under the PBGC Missing Participant program. Now, as we are allocating excess assets, he shows up. My review of the MP instructions is that the Plan *can* send the allocation of excess to PBGC, but I do not see any requirement to do so. My opinion is that we should pay the excess directly to participant (with properly executed form) since that is much simpler and avoids having the PBGC track down 2 payments.

Any comments?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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