Waiver of 30-day notice and the new tax notice

[Guest beppie_stark]

We have required that participants make an affirmative election to waive the 30-day waiting period by checking a box on the distribution form. If the waiver box is not checked, we hold the distribution for 30-days. I realize this is a conservative approach and that many distribution forms include the waiver in the final certifications.

Now the latest safe-harbor Special Tax Notice, in the "Your Right to Waive the 30-Day Notice Period" section says a participant may waive the notice period by "making an affirmative election indicating whether or not (he) wishes to make a direct rollover."

To me this seems to imply that a waiver of the 30-day notice (affirmative or in the certifications) is not necessary on any distribution form with an election of a form of payment. In other words the only time the 30-day notice period will come into play is in default payments under $5000.

Does any one interpret this differently? Any one have an opinion on the advisability of relying on the author of the notice for administrative direction?