Return of automatic deferrals

[Guest Sieve]

Is there anything out there that softens the regs' EACA requirements (such as universal availability) that would allow a plan the ability to return automatic deferrals within 90 days without a full-blown EACA?

[K2retire]

As I recall PPA creating the "permissible withdrawal" was one of the big advantages of offering an EACA. It seems unlikely that it would be allowed otherwise, although I believe some of the EACA rules have softened of late.

[Kevin C]

The final regs published 2/24/2009 softened the EACA requirements. I thought the preamble discussion was more clear about the changes than the regulations themselves. The regulations are not in effect yet, but following the final regulations is deemed to be a good faith interpretation of the code.