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Involuntary cash outs without consent

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403(b) Plan has been operated as if it allowed involuntary cash outs of small amounts without consent, however plan document does not include this provision. How is this corrected? 

Under Rev. Proc. 2019-19, it appears it should be corrected according to Section .07 of Appendix A, which addresses failure to obtain participant consent under 411(a)(11).  But the correction method described is to offer participant a choice between consenting to the distribution already made and receiving a QJSA. Receiving a QJSA makes no sense in this situation.

Any thoughts?

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