Based on the age of the participant according to your records; e.g. over 59 1/2 would be "normal." Under, "premature, no known exception."
Ironically, your reporting of the distribution is the last possible chance that the participant may be made aware of the funds existence. Unfortunately, he will find out about them by getting a deficiency notice from the IRS.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.