402(f) Rollover Notice

[Guest bobolink]

OK. Sec. 1102 of PPA amended Code Sec 417(a)(6)(A) by striking "90 day" and inserting "180 day" and modified the regs sec 1.402(f), 1.411(a)-11© and 1.417(e)-1(b) by substituting 180 days for 90 days each place it appears. The problem is 90 days does not appear in reg sec 1.402(f)- it's 60 days. Making the matter worse, Section VII of Notice 2007-7 states that PPA 1102 provides that a notice required to be provided under Sec 402(f), 411(a)(11) or 417 may be provided as much as 180 days before the annuity starting date.

How to reconcile? Statutory construction over agency guidance? Hmmmmmmm.

[Bird]

1.402(f) doesn't contain the timing rules for the notice, so I guess that reference is superfluous, but I don't think it's really a problem. FWIW

[Guest bobolink]

Kindly disregard this chain. Errors abound.