Merger of DCP

[J2D2]

As a general rule, IRS Form 5310-A must be filed at least 30 days prior to a plan merger. The filing requirement is waived for the merger of defined contribution plans that meets requirements specified in the 5310-A instructions. Does the waiver of the 5310-A filing requirement also mean that the merger could take place contemporaneously? For example, could an employer adopt merger resolutions on January 31, 2002 and make the merger effective the same day?

I realize that there are GUST/EGTRRA update issues for both plans, but, for now, just want to focus on this (potential) timing issue.

Thanks.