What can and can't a plan sponsor do re: suspending distributions from

[John A]

What can and can't a plan sponsor do regarding suspending distributions from a defined contribution plan when the plan termination is submitted to the IRS? Can distributions be stopped (pending IRS approval) as of the date of plan termination, as of the date the 5310 is filed, or any date the plan sponsor chooses? Can a plan sponsor refuse to pay the distribution until IRS approval to a participant that terminates employment after the suspension of distributions (does this depend on the document)? Does a plan sponsor have to adopt a plan amendment and/or a written policy in order to suspend deferrals? If all participants terminated employment due to the business closing down and the plan document contained a provision calling for distribution as soon as practicable after termination of employment, can the plan sponsor suspend distributions until IRS approval is obtained? Are there any other issues a plan sponsor should consider prior to deciding to suspend distributions until IRS approval is obtained?