Death benefit - no named beneficiary, per default terms of the plan will go to a child who is a minor

Monday brain cramp (although the cramp is likely permanent...)

A lot of angst here over a small amount of money, but the question has come up if the death benefit can be directly rolled over to a trust for the benefit of the minor, or can it be designated as a beneficiary IRA? I'm really not sure on this one, due to the fact that there was no "designated beneficiary" by the participant. I believe it has to be under the control of a guardian/Trustee until age of majority regardless of rollover status. Thoughts? Thanks!  

Update - after having done some additional research, this seems to get complicated even further. It seems like it will be ultimately governed by state law, since ERISA doesn't appear to specify specific handling. So we'll need to tell the Plan Administrator and client to consult legal counsel. Seems like the legal guardian (and there is one) can make it easy (on the advice of counsel) by either setting up a UGMA trust/custodial account, or direct a rollover to an inherited IRA set up for the minor beneficiary?

The times I have seen this the legal guardian can set up an IRA for the minor. 

No legal expert, but I believe there may be a need to clarify whether such "guardian" is responsible for the minor's person or the minor's estate.

Don’t assume a State’s law applies. If ERISA governs the employment-based retirement plan, ERISA supersedes and preempts States’ laws.

If ERISA governs, a plan’s administrator administers the plan according to its governing documents.

A typical plan document states provisions for recognizing a natural or appointed conservator, natural or appointed guardian, UTMA custodian, or other fiduciary to act for a minor.

A plan’s administrator might, in some circumstances, consider a State’s law or States’ laws to form a finding about whether a person is empowered to act for the minor.

When a death benefit is a small amount, a plan’s administrator might prudently form some risk-tolerant practical decisions.

The administrator’s focus is on whether it is dealing with a satisfactory claimant and payee.

That fiduciary of the minor sorts out what is or isn’t proper, and is or isn’t prudent, about a rollover to an IRA or a transfer into a trust or UTMA account.

This is not advice to anyone.

Building on Peter's excellent point, a plan document can include a provision dealing with a particular aspect of plan administration, including paying the money to a guardian, trustee, parent, grandparent or an UTMA custodian, to name a few. To the extent the plan document contains a provision which is not contrary to ERISA and is meant to facilitate plan administration, it can be accorded status similar to that of ERISA in the sense that it could preempt state law. While the typical plan document allows a responsible person to act for the minor beneficiary, an atypical plan provision can do more to facilitate the administration of a benefit in such case. 

Thank you for your kind words.

When I write or edit a plan’s governing documents, I write custom beneficiary provisions. That’s so even when I’m stuck with reacting to an IRS-preapproved document.

Beyond allowing ways to help claimants and get efficient plan administration, one can write beneficiary provisions to narrow the plan administrator’s or claims administrator’s scope and so lessen its liability exposure.

The beneficiary provisions are not one-size-fits-all because different plans face different challenges, and different administrator have different needs.