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The freeze amendment and 204(h) notice should indicate what is being frozen after June 30. I would normally expect it to say that service and compensation are not considered after the freeze date. However, since 401(a)(26) is so poorly defined it's not that big of a stretch to argue that compensation should be measured for only the period during which the benefit was actually accrued.

I'd prefer a separate paper trail, especially since one $4M transaction will "look" to be over the 415 limit. But I don't think you need two transactions, especially if you have her completed elections for both her benefit and her husband's as his beneficiary and can account for the two even if they are sent in 1 wire/check. Though you will need separate 1099-Rs.

Peter, the attached chart from one of your earlier posts on this topic is illustrative. You list 4 columns headed Early? / Rely? / Excuse? / Repay? and hardships are the only withdrawals with the pattern Yes / Yes / No / No Hardships, unlike the other withdrawal reasons, are subject to the 10% excise tax on early withdrawals, and most other withdrawals available before a distributable event or age 59 1/2 allow for repayment of amounts to the plan while hardships do not. One can infer from these rules that hardships are a bad deal versus the other withdrawal reasons. Hardships have added taxes and cannot be repaid. But this is not the question you asked. On balance, hardships have flipped into the group of permitting self-certification. I would say that a plan - for all withdrawals where there is a choice - should choose to allow or choose to not allow self-certification . Consistency will be the key decision. If a plan picks self-certification for some kinds of withdrawals where it is allowed and not for others, participants quickly will figure out that asking for a kind of distribution that allows self-certification is the easier path to getting money out of the plan and possibly paying less in taxes, too. Distributions added or changed by SECURE 2019 and 2022-1.pdf

I believe you can make any source eligible for ROTH conversion, though I think it does have to be 100% vested to convert. However, you do have to preserve the pre-ROTH characteristics (such as distribution timing) of the funds being converted so you'll likely need to track a separate ROTH source for each source of funds that is converted to ROTH.

Is $2,948.26 the monthly amount he would have received if the 5-year C&L annuity started on his required beginning date, and is the $43,342.26 single sum simply the make-up annuity payments (with interest on the retro payments from required beginning date to the annuity commencement date)? (Since you didn't say, when was this person's required beginning date?) If so....the deemed RMD (subject to excess accumulation excise tax in each year from the year containing the required beginning date until 2022) would be 9-months of payments for the year containing his required beginning date, and, assuming the required beginning date was not 4/1/22, it would be 12-months' worth of payments for each subsequent year until the end of 2022. The RMD for 2023 would be equal to the 12 months of the annuity payments for 2023. Since the lump sum is to make up for annuity payments that were supposed to have been received from required beginning date until the benefit commencement date and that would not have been eligible for rollover in the first place, none of that lump sum amount would be eligible for rollover.

I think what that's less-than-simply saying is, if the plan doesn't make its "computed more frequently than annually" match by the end of the next quarter (as we normally see required with pay period match computations), then by failing on that timing provision, the plan is essentially falling back into an annual computation and the true-up would be required. (Which makes sense because the plan would have bailed on its obligation as a pay-period calculator....and an annual calculation is what then leads to needing true-ups in the first place.)