1099-R For Missing Participants (Forced Rollover)

[Stash026]

I had a Plan terminate last year and we were unable to locate about 20 participants.  We went through the searches, etc. and ultimately had the money rolled into IRA in their name so the Plan could terminate.  What is the requirement for 1099-R for these rollovers?  Do we do the 1099 with the last known address and just stick it in a file?  Is the 1099 required in this circumstance?

Thanks everyone!

[ESOP Guy]

Yes, it is required.  

[CuseFan]

1099R reporting goes to both the employee and the IRS, so even if you "filed" the undeliverable employee copy (not recommended) you still owe the IRS a copy.

[Stash026]

What address would you use if we don't have a valid address?  Would you use the employer's address?

[JulesInCNY]

I would still use the last known address for the lost participant.   very rare we have absolutely nothing to start with, but I guess in that rare event I'd have no choice but to use the client's address.  definitely still have to file one anyway, more for the IRS than anybody else.