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I have a plan I want to terminate 12-31-18 and I want to freeze accruals 11-15.  I am submitting to the IRS but the plan is not covered by the PBGC.

I have a 204h notice prepared and set to go out 10-31.

Is there a NOIT when the plan is not covered by the PBGC?  Or another notification to the participants that the plan is terminating?  That should be issued 60-90 days in advance?

I know I have to do a notice to interested parties 10 to 24 days prior to my IRS submission.

Can I submit my plan termination paperwork to the IRS before the plan termination date?  

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