Does the Blackout Notice apply to a terminating plan?

[katieinny]

More questions about the terminating DC plan.

The participants in the terminating plan will become participants in the new employer's plan as soon as they can get things converted over for payroll purposes, which could take a few weeks. So there will be a few weeks when no deferrals take place. And since the terminating plan is doing a 5310 submission, distributions won't be made until the determination letter is issued.

Loan payments must continue to be made during this interim period, which could be several months, but no new loans or distributions will be processed.

Does that mean that a blackout notice is required?

[E as in ERISA]

By definition, "blackout" only includes temporary suspensions, not permanent suspensions.