Failure to distribute account at NRA

[Jeff Kirtner]

A participant severed employment some years before attaining the NRA of 65. The 401k plan requires lump sum distribution of all accounts at NRA if the accounts haven't been distributed earlier. Participant is now 71 but no distribution has been made. There has now been an additional failure to make an RMD. The issue is how to correct the failures. It is clear the participant needs to receive a distribution of the entire account, some of which will be an RMD. But I have the following questions: (a) is participant entitled to any deemed earnings on the account balance as it was at 65 (when it should have been distributed to him); (b) assuming the value of the account is less now than it was at 65, is the employer required to make up the difference (if relevant, at all times the participant self-directed investment of the participant's accounts); and © given that this was one participant out of many, any reason not to consider the operational failure "insignficant" and thus correctable years later through SCP?