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  1. Biz Develop Consultant BJF
    We have an participant who worked for Company A (of a control group) and her job was transferred to Company B (of a control group). Company A sponsors a DC Plan with section 401(k) and Company B sponsors a DC Plan with employer source (only) funds. Said participant is seeking to take a withdrawal of her balance from Company A 401(k) Plan and the question arose about her having a distributable event. If review of the IRS guidance, https://www.irs.gov/pub/irs-drop/n-02-4.pdf, Section III seems to suggest that if both companies have section 401(k) then no distributable event is present. However, company B only has employer source funds and no 401(k). Am I interpreting incorrectly here?
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