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transfer between plans of same employer

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NFP ER has a non-ERISA 403(b) plan.  For many reasons, this arrangement is no longer satisfactory and they want to 'start fresh'.  They would like to freeze the current plan (I know I can't terminate it and get it all paid out within 12 months) and install a new ERISA 403(b) plan on a single vendor platform.  The participants can transfer their accounts from old plan to new plan even without a distributable event, right?  The catch is that we'd have to preserve distribution options from the old accounts for participants who are still employed at the time of the transfer.


Am I missing anything?  Thanks.

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