We have a client that is terminating its SERP this year. The company has been using search firms to locate missing participants, but we are preparing for the possibility that a few may not be located by year end. One approach is to report the distribution amount as a taxable distribution to the IRS and pay the benefit, less tax withholding, to a bank account for the participant's benefit. Does anyone have any comments or suggestions?

IRS letter forwarding program:
http://www.irs.gov/retirement/article/0,,id=110139,00.html
Free if less than 50 in a 12-month period. Much more if the number exceeds 50.

BTW, the SSA also has a program, that costs $25 per.