severance vs termination from service/employment

[Guest bobolink]

This issue has been coming up with greater frequency of late and I am trying to track down the source. Basically, IRS DL examiners are requiring plans to replace "termination of employment" with "severance from employment". We like to say "separation from service" which is ok some of the time, not ok others. When I look for the origin of this position, I get bogged down in 409A. Can anyone point me in the right direction?

[QDROphile]

"Separation from service" was a concept under obsolete 401(k) regulations, associated with the "same desk" rule. "Severance from employment" is newer terminology in regulations. I will not take kindly to directions to use the phrase in place of termination of employment, except perhaps in the 409A context.