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True dat.

Well, I guess the IRS has only updated the language once this year in Notice 2020-62, although FTW gave us updated language in February for the items noted above by C. B. Zeller, with his quote coming from the Notice (just issued recently). They also added some text about "disasters" reflecting the CARES Act and made some other tweaks. (My point isn't well made but I was confused when reading this thread, as I thought the SECURE Act language was already provided by the IRS.) In any event it is one of those things where we do our best (we will start using the new notices immediately) but have no concerns at all about whether an "old" one slipped out. I think for there to be any consequences someone would have to sue, which implies they read the notice, which is a preposterous assumption.

You never need to use it, it's only a safe harbor. Any differences between your notice and the model take yours out of the safe harbor, but don't necessarily make it invalid.