Leaderboard

I would imagine that in the final resolutions by the board of directors, certain persons were authorized by the board to take all actions necessary to wind up the affairs of the corporation. I'd look to the final meeting minutes, and then have the person or persons so authorized by the board sign the plan documents. If it is not a real life situation yet, before it becomes one advise the sponsor to have the board specifically appoint someone to act on its behalf to wind up the plan and put this in the minutes.

The first issue is that most SEPs have an exclusive plan requirement, in which case the contribution limit is $0, If not for that issue, the limit would depend on whether or not the DB plan were subject to PBGC, first. If so, no combined limit. If not, either the combined contribution must be limited to 31% or the DC is limited to 6% or less and the DB has it's independent limits.

A 401(k) plan is just a PSP with a 401(k) provision. Why can't you amend a "401(k) plan" to no longer offer deferrals. Mid-year of a safe harbor plan notwithstanding.