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Term date


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Hi, 

Plan terminated due to asset sale and the termination date was 06/30/2022.  the client failed the 415 testing because the testing was done for the period 01/01/2022-06/30/2022, since the plan failed testing they want to change the termination date to 09/30/2022.  as per the client if they had the termination date been set at September 30, 2022, the prorated annual limit of $61,000 would have been $45,750 and the 415 Total Excess column on the far right of this calculation would have been $0 for everyone.

The termination process has already been started and notification has been sent to participants and participants have already started requesting for distribution.  Can they change the term date now?  what will be the repercussion? 

Thank you.

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