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Small plans still may be required to issue Forms 1096, 1099-R, and 945, which will use the Trust EIN. I'll also note that the proposed changes to Form 5500 includes a line for the Trust EIN, even though the 5500 itself uses the sponsor EIN.

Wow, I used "allowed" a bunch right there...Better query: Once CRDs were effective for a plan, was it permissible to remove them before their statutory expiration? Wouldn't that be a cut-back in benefits? Or were they specifically allowed to be put it and taken away at the sponsor's or administrator's discretion?

I vote for your idea. If one uses IRS-preapproved documents and falls into the IRS’s remedial-amendment regime, eventually some document states what the plan’s sponsor and administrator (typically, the employer) treated the plan as having provided. And that document should follow what was assumed to have been provided. So: From {the date the implied assent became effective} to {the date the plan’s sponsor revoked the implied assent}, . . . .