Rollover Q

[Guest lvegas]

Assume ER (for whatever reason) has 2 money purchase pension plans covering different portions of its workforce (A & B ). ER wants to terminate A and permit participants in A to roll their accounts into B prior to termination. A covers terminated vested participants who are not covered by B. Can those vested terms roll their accounts from A into B without violating the exclusive benefit rule of 401(a) (or other rules) even though they aren't employees anymore and otherwise have no nexus to B? Or is an elective transfer needed under the 411(d)-4 regs?