60-day requirement to notify participants of a material reduction

[Guest calcu]

For purposes of measuring the 60-day SMM distribution requirement if there has been a material reduction in benefits, the regs state that the distribution must take place no later than "60 days after the date of adoption of the modification or change." Does this mean that if I sign an amendment reducing medical benefits on October 1, 2005, effective January 1, 2006 that the 60 day starts to tick on January 1, 2006 since that is the effective date? Or October 1, 2006 since that is the date the amendment was signed approving the reduction?

Thanks,