Lump-sum to annuity or longer annuity: 5 year postponement required?

[Guest jcarlos]

Does anyone know: Has there been any further clarification on Election changes under 409A?

Specifically, if a participant changes his election from a lump sum to an annuity within the 12 month effective/in-advance time period, is this considered subject to the 5 year change in form requirement? Or, similarly, if a participant lengthens his annuity payments from, for example, 5 to 10 years, is this subject to the 5 year change in form requirement.

Is there anything to hang my hat on out there?

[Guest Harry O]

No guidance yet. But stay tuned . . . proposed regs to be released in mid-September.

[Guest jfsinger]

Harry O,

How sure are you that the regs are coming mid-Sept?

Joe

[Guest Harry O]

Pretty certain.