PPA Cash Balance Plans: Notice 2007-6

[ERISA25]

Notice 2007-6 provides cutback relief for an amendment that eliminates the excess of the participant's hypothetical account balance with respect to distributions made after the later of August 17, 2006 or the effective date of the amendment.

My question has to do with "distributions made after the later of August 17, 2006." With regard to this language, what is considered the date of distribution? Is it the benefit commencement date or is it the date the money is actually paid to the participant. For example, if a participant makes a request for payment on August 14, 2006, but does not receive the money until August 20, 2006, what is the date of distribution for purposes of PPA relief? I know some plans have provisions that say the benefits will be paid as soon as administratively possible after the request or benefit commencement date.

Any thoughts. (Please include citations to any authority.)