I think if the Sponsor's RK is having a hard time allocating the money to the participant accounts then it may be time for a new RK. The DOL's rule targeted only the Plan Sponsors, but no the RKs. It may be a lot to ask for some RKs to allocation within X number of days, depending on what systems or investments they use.
While I agree with David, generally, 1) the PLAN still needs counsel to determine the effect and effectiveness of the disclaimer should it arrive; and 2) these forums provide an opportunity for learning, so context (estate tax, income tax and the like can be helpful in understanding).