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The plan may, in various instances (terminating participant, participant undergoing divorce or other personal change, plan termination, global pandemic that gets even worse) need a short-term, highly liquid investment, so probably imprudent not to include as an option, but prudence is based on facts and circumstances.

TPApril, where the non-5% owner employee terminates after RBD, the first distribution year is year of termination, so here 2020, but RBD is April 1 of next year, here 2021. Also, the actuarial adjustment required for delayed benefits stayed at 70-1/2; did not move with the RBD to 72.

Make sure he signs/dates an election form prior to doing that.

The plan has to be adopted and effective before money is withheld from his pay; that's about all.

Without going back to check, iirc code M has been around since the 2018 Form 1099-R following the changes made by TCJA. Regardless, the only difference between a code M and a code 1/2/7 is that the participant gets extra time to roll it over. If they were not intending to roll it over then it doesn't matter. If they do want to roll it over and are going to rely on the extended deadline, they might be able to get away with just attaching a note to their tax return, but it would be safer to issue a corrected 1099-R.

@ERISAQuestions1234 The preamble to the final regs addresses that point. You look only to the number of affected individuals associated with each particular covered entity when determining whether the breach involves 500 or more residents of a state of jurisdiction. https://www.federalregister.gov/documents/2013/01/25/2013-01073/modifications-to-the-hipaa-privacy-security-enforcement-and-breach-notification-rules-under-the The Department also recognized that in some cases a breach may occur at a business associate and involve the protected health information of multiple covered entities. In such cases, a covered entity involved would only be required to provide notification to the media if the information breached included the protected health information of more than 500 individuals located in any one State or jurisdiction. For example, if a business associate discovers a breach affecting 800 individuals in a State, the business associate must notify the appropriate covered entity (or covered entities) subject to § 164.410 (discussed below). If 450 of the affected individuals are patients of one covered entity and the remaining 350 are patients of another covered entity, because the breach has not affected more than 500 individuals at either covered entity, there is no obligation to provide notification to the media under this section. More details generally on the covered entity's notice obligations here: https://www.theabdteam.com/blog/hipaa-breach-notifications-for-employers/