Timing of termination of PSP, application for determination letter and ERISA Notice

[billfgrady]

An employer sponsors a money purchase pension plan (volume submitter), which it amended and restated for GUST on September 30, 2003. The MPPP is a calendar year plan. The employer would like to terminate the plan as of 12/31/03 and then apply for a determination letter speaking to the termination and the GUST amendment prior to the deadline for submitting for a GUST determination letter of January 31, 2004. Pending the receipt of a favorable determination letter, the employees would start rolling their funds out of the plan as soon as is administratively feasible. Subsequently, the employer would file a final Form 5500 for 2004 (short plan year).

When does the employer need to issue ERISA 204(h) Notices to Plan participants? Is the plan really terminated as of 12/31/03 because there are consent minutes of directors saying that the termination of the Plan is effective as of that date and that the employer won't make any further contributions? Or is the "termination" effective when all of the participants funds are rolled out of the plan? Appreciate that there are no employees who will qualify for a contribution in 2004 (end of the year requirement).

[WDIK]

When do accruals under the plan cease?

Edit: (BTW, PSP or MPPP?)