Money Purchase Plan: Termination and Distribution

[Guest benefitstudent]

The plan sponsor is liquidating and may be administratively insolvent.

The plan is to be amended and submitted for a final determination letter. Is it possible for the plan to be amended to provide for partial distributions pending the receipt of the determination letter? Would this be a significant risk to the issuance of the determinaton letter? May those eligible for retirement under the terms of the plan be processed as usual (assuming there is anyone at the company to process the request) and paid their account balances?

Assuming there is no money in the estate and no one left at the company, how should this be handled? An independent fiduciary paid from plan assets?

This is a difficult situation imposing great hardship on participants. Any suggestions would be greatly appreciated.