IRS Examination- Qualification Issues

[Guest Gumby]

Does anyone have any recent experience with what kind of issues found during an examination that the IRS will consider a true "qualification issue"? Would a failure to make RMDs where the participant was notified of the need to do so but did not take action to receive a distribution constitute a serious qualification issue? The plan document provides that RMDs will be made and they have been made except for these few instances where the participant took no action. Apparently the plan did not proactively and unilaterally process RMDs. Even if the missed distributions are low, I am not sure whether this can/will be used to extract large sanctions from the plan sponsor. Any thoughts?