Restriction Question

[Penman2006]

On April 1 a plan becomes restricted from paying full lump sums. What about participants that received distribution election forms prior to 4/1, at that time were entitled to a full LS, but did not return their forms by 4/1. Can they get the full lump sum payment paid to them after 4/1? Would their forms have to be signed before 4/1 or just provided before 4/1?

[Effen]

I think it is the date paid. If it isn't paid by 3/31, I think it is restricted.

For our clients who are close to the 80%, we told them about a month ago that we would be delaying lump sum calcs until we know for sure if benefits will be restricted.