I have a plan that restricts the timing of a distribution until after the close of the plan year following a 1 year break in service if termination is for reasons other than death, disability, or retirement. If termination is due to death, disability, or retirement, then the distribution can be paid as soon as administratively feasible.
The Normal Retirement age of the plan is age 62. A participant terms at the age of 61(not retirement age set by the plan). They wait and submit a distribution request upon turning age 62, but haven't yet incurred the 1 year break in service. Per the plan provisions, do they have to wait for that break in service and then be paid following the close of the plan year, or does the timing allow for them to be paid as they now reached Normal Retirement age of the plan. The employer notated "retirement" as the distribution reason, but at separation from employment, he wasn't the NRA of the plan. Thoughts on the timing of this distribution?
