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if my understanding of the 'logic' [ha ha ha ha ha] behind this is the 'new' people never received a notice. you are now making them eligible so they receive a notice. this is different than 'amending' the plan that changes something else that would have been in the notice. And there is noting in the regs about issuing a new notice if you 'changed' something that was in the notice. or at least that is the best I can figure behind the logic. I just wish they would say , ok, you can change stuff, and if you do so, update the safe harbor notice if needed. ................. and for those out there, have a blessed Easter (or a wonderful Passover if that is your background) have gotten my special Resurrection cookies made (Springerle - chocolate version) and home made Potica Bread (walnut filled bread) well, I'm not sure how to paste images any more, this is a link to the cookie design - makes a good 7 1/2 inch cookie. http://houseonthehill.net/images/products/preview/m2061.jpg

I do not believe the IR-Annuity and the IR-Account can be aggregated based on the reasoning in the following regulations that treats an annuity contract purchased inside of an IRA as separate and distict for RMD purposes once annuitized. It would appear that there are two separate plans here as well. Thus, IMO, the two IRAs can not be aggregated for purposes of calculating the RMD or be used to offset against one another RMD amounts; there is no excess from the annuity regardless of how it is annuitized. Hope this helps. §1.401(a)(9)-6, Q&A 12 -- zzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz §1.401(a)(9)-8, Q&A 2(a)(3) -- ).