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Discretion to eliminate single sum


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Regs. 1.411(d)-4, Q&A-2, subparagraph (d)(1) provides an ESOP exception to the protected benefit rules. "The employer eliminates, or retains the discretion to eliminate, with respect to all participants, a single sum optional form or installment optional form...."

QUESTION: Does this also allow the employer to change the commencement date of payments in the event of termination of employment from the end of the plan year in which the separation occurred to the year after the close of the plan year which is the fifth plan year following the plan year during which the participant separated from service?

Any thoughts on this and on (d)(2)(ii) of this same Q&A-2 (which seems to impose quite an administrative burden) would be appreciated.

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