It has always been my practice to mail direct rollovers to the financial institution or trustees of the qualified plan accepting the rollover. My new employer has instructed me to mail rollover checks made payable to the financial institution to the participant. My understanding was that a rollover had to be a "trustee to trustee" transfer and that the participant literally could not touch the check. Is it okay to mail the rollover check to the participant?

"...Giving the check to the distributee for delivery to the eligible retirement plan is considered reasonable provided that the check is made payable to the trustee of the eligible retirement plan for the benefit of the distributee." Reg. Sect. 1.401(a)(31)-1, A-4