Distribution Notice and Option Forms

[Guest cjk]

A participant terminates employment halfway through the plan year. Distribution forms are provided and the distribution of the entire account balance is made within the 30-90 day period after the notice was given. At the end of the year the participant receives an allocation of the employer contribution for that year. The plan wants to distribute this allocation to the participant. Do new distribution forms need to be provided if more than 90 days has expired since the original distribution form was provided to the participant or can the situation be interprested to fall within the exception for a "reasonsable administrative delay" referred to in Treas. Regs. §§1.401(a)-20, A-10(B)(3) and 1.411(a)-11©(2)(iv)?

[Blinky the 3-eyed Fish]

My opinion is new forms must be given.