I stood personally in the Escapees Legal Dept. office to discuss this very concern in October 2019. Paraphrasing: The female attorney, sorry don't recall her name, told me directly that Escapees has a form letter, if you will, that addresses this concern and has always solved the situation with Schwab and many other institutions. She went on to say that it is a matter of time until all institutions will be contacted by the Feds to address the issue and when the non-compliance fines get large enough, each institution will be searching for a solution. This matter of time may well be longer that any individual's lifetime. She also stated that this Escapees Form has been 100% accepted each time utilized and had been used many many times.
I did not ask if there was a fee. I use #50xx for box number. I am very comfortable for when and if the situation arises.
P.S. Evidently this does not arise frequently, as the first person I saw in the legal office wasn't aware of the situation. On the other hand may have been new to the office.