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Adding Lump Sum Option after Plan Termination process has begun


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An employer is terminating a plan. His plan does not currently permit lump sums, if the lump sum would exceed a certain amount. The employer considering whether he wants to add the lump sum option for all employees.

In the meantime, the employer is sending out Notice of Plan Benefits (as required by the PBGC). The Notice going to the employees who are over the lump sum threshhold says nothing about lump sums.

Does the fact that the employer has sent out an NOPB that says nothing about a lump sum option cause the employer problems, if the employer later decides to add the lump sum option?

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