EE working on VISA doesn't want to open account

Our client has a PS 401(k) plan with 3% SH non-elective.  They have a new employee with a Visa; she is from Germany.  She has chosen to defer, but does not want to open an account (TD Ameritrade).  They have her first deferrals, which have been held for a couple weeks, as well as her 3% SH.  But there is presently no account for them to deposit the money to.

Can participant continue to defer if she refuses to open an account?  How long can ER hold the money before it becomes a problem?  Even if she does not defer, what do they do with her SH?  (Plan excludes "non-resident aliens" - she is here legally as a resident alien.

All thoughts and suggestions welcome.

9 minutes ago, Cynchbeast said:

She has chosen to defer, but does not want to open an account (TD Ameritrade).

Why is it the employee's responsibility to open an account? The plan has to have a trustee. This is the trustee's duty.

10 minutes ago, Cynchbeast said:

How long can ER hold the money before it becomes a problem?

DOL rules on this are quite clear - it has to be deposited as soon as administratively feasible. There is a 7-business day safe harbor for small plans.

Does the Plan have default investment language?