PPA 2006 - In-service withdrawals at 62

[PMC]

The PPA liberalized the withdrawal rules for pension plans by permitting in-service withdrawals upon attaining age 62. In reading the Technical Explanation it refers to "pension" plans permitting such a distribution.

May be taking this too literal but what about a MPP that was merged or amended into a PSP/401(k) - that MPP account balanced that was transferred had to follow the withdrawal restrictions of RR 94-76. But that MPP account balance is now part of a Profit Sharing Plan. It would seem odd that the MPP account balance that was transferred and now part of a PSP would not be available subject to this new rule but just wanted to check.

[Bird]

I think it is reasonable to assume that merged MP assets in a PS plan can be distributed under the new law. I think the same reasoning that didn't allow distributions of these monies is what now (well, in 2007) allows such distributions - that said money is still part of a "pension" plan, even though it's within a PS plan.