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I suppose it depends on state law. Here in California the employer is forced to follow the employee's wishes. If that results in a default, so be it.

Could never pass 410(b) anyway - too many Red Sox fans in the world! (And those who AREN'T Red Sox fans really want to be - they just don't dare state it publicly...)

I completely agree. I've been on the ASPPA conference committee for 4 years now and will serve as a co-chair for the next 2 years before rotating off. The lack of cooperation from government the last several years has been incredibly frustrating. People are fine with following the rules to get the benefits. But we need to know what the rules are.

Thanks for the insight. But, this is, exactly, what we're trying to avoid so that we don't have to hire attorneys. Not being argumentative, but you wouldn't want to hire an actuary to confirm that 2 plus 2 is 4. Heck, I can provide this information to my clients for free :-) Situations such as this, where there is seemingly an intentional refusal to offer concrete guidance, handicaps us from providing our clients the accurate and complete information they seek. If the IRS gives us the guidance, then we can avoid trouble; which is often my focus. But, thanks for the insight. Again, I'm not being argumentative, but merely voicing frustration on what appears to amount to a lack of initiative from the IRS. Good Luck!

I seriously doubt you are looking to do that. The sane approach is to bring over accumulated data (years of service etc) with the census and account data and move forward. You might want to re-create the last year from your old system on the new but you can just start with the next year.