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Posted

Generally, you would have 180 days from the end of the plan year in which the amended provision takes effect, to distribute a new SMM. However, in the interest of promoting good plan administrator practices, I would notify the participants as soon as possible either with an SMM or by memo.

Posted

I think what you are asking is whether there is a special advance notice requirement, similar to a 204(h) notice. The answer is no.

I agree with the prior posters that it is good practice to notify participants as soon as possible, and of course do a SMM.

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