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1.401(a)(4)-5(b) - restricted distributions


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Do the restricted participant distribution rules of 1.401(a)4-5(B) apply to church plans?

I have a new church plan client (db) which is currently underfunded and the only HCE would like to take a lump sum. Based on my reading of the regulations, I think these provisions apply to church plan, but I'm not positive. Has anyone ever faced this?

He was not real happy when I brought this up.

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