A 401k plan has decided to terminate on 1/1/2020, the company is closing. There are only 3 participants, one is terminated. The terminated participant submitted distribution paperwork on 10/31/2019 to move his account to an IRA, but the 401k provider froze the plan as soon as they were notified of a plan termination. The other two participants are also submitting paper work to roll their money out (one is a part owner). Does the 401k provider have the right to freeze the plan ? When can the participants expect to roll their money over, after 1/1/2020.