FAB 2009-02 excluded participants in a plan term situation

[AlbanyConsultant]

An ERISA 403b plan where we merrily have been excluding a few participants from the 5500 count for the past few years because they terminated in 2004 and 2005 and had their balances only in old annuity contracts is looking to terminate.  All of the other participants with balances are active on the mutual fund platform so we were all excited to have an easy plan termination... and then someone remembered these stragglers.  Is there any way to consider these few people already in possession of their accounts so that the plan can be terminated and paid out?  Maybe with a notice to them to give them a heads-up that the plan is officially terminated?