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If the plan says that changes to deferrals can be made on entry dates (and presumably only on entry dates; I can't imagine it saying that and then somewhere else saying "oh but you can change any time"), I'd say you have answered your question. But that is easily amended. FWIW I've never seen the rationale for limiting changes.

Well if you want to get technical, and if we aren't in a technical biz then I don't know; I mean, I've seen people fuss over things way less significant than this...the plan still exists until it is term'd; just taking money out doesn't terminate it. So what are the consequences? Well, the doc should be maintained and updated...if not, the plan is DQd, and the consequences would be...taxation of the $0 in the plan, so not exactly a nightmare scenario. But I think there are potential issues with not terminating it and failing to update for SECURE and/or CARES. As a side note, I try to avoid scenarios where "We find out today that he retired and took his money out in February." Anyway, I'd formally terminate it; don't see it being worth taking any chances...and could have prepared a termination resolution, maybe 3, in the time it took to ask and answer the question.

Disagree. Short-term noise. Long-term, could become much more common.

I also say, "We do 401(k) Plans" and add "we are the compliance and government reporting folks" because yes, otherwise, the listener believes we sell investment products.

Formula for determining earnings on refunds is earnings * excess/(Beginning balance plus contributions for the plan year). What does contributions for the plan year mean? Does it have to recognize all contributions including receivables? If not, why not?