Suspend RMDs

[PMC]

Took over a plan where the required beginning date is defined based on the TRA '86 of age age 70 1/2, regardless of whether the 'EE has retired. Participants have been paid their RMDs based on that RBD. The employer now (2006) wants to amend that provision to the SBPJA date of the later of 70 1/2 or retires.

Can participants, who are over age 70 1/2 but not yet retired, now elect to suspend their RMDs because of the amendment? Or is it too late for those participants because the plan wasn't amended during the GUST remedial amendment period and such a participant did not make an election during that RAP?