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An employer would typically choose to sponsor a qualified plan where they see the benefit of doing so. Choosing a myRA or other goverment sponsored option would have no effect on that decision in the same manner as a current IRA option does today. Any SIMPLE IRA or SEP sponsor is a potential client for me tomorrow. Once they get their feet wet, they will jump into the pool sooner or later.

I often explain to my clients that part of my function is to protect them from themselves :-) Good Luck!

You can't amend an existing plan from pro-rata to groups after the end of the year, and you can't start a new plan after the end of the year. Period.

Again, it's the rest of the document that says what you can and can't take - in addition to the required amount, which is a minimum under the law, notwithstanding anything else in the plan. The minimum language says "you must take X even if the rest of the document says you can't take anything." It seems a stretch to me that RMD language which includes the word "minimum" effectively adds a lump sum option at age 70 1/2. That's definitely not the intent - the intent is to make sure taxes aren't deferred indefinitely. As far as the IRS Q&A, there is no doubt that they don't always think the questions through, and I think this is one of those instances. Having said all that, I don't know that they would notice or care if they looked at this on audit. I know we have in-service provisions at NRA for all or almost all of our plans, and I think that's the norm, so it's probably a rare event.