Failure to Provide 401(f) Notice

[lkpittman]

We have a Profit-Sharing sponsor who decided to "terminate" the plan on his own and allow participants to receive distributions/rollovers without providing a written 402(f) notice to participants. He claims that everyone rolled their money over--it remains to be seen whether he did these as "direct rollovers" or made out checks to participants. In any event, I'm assuming this is not a qualification error as defined in Rev. Proc. 2001-17 and is simply an error subject to the penalty described in 6652(i) ($100 for each failure). Can someone confirm that this is not a qualification failure?