242(b) Election at Plan Termination

[Guest DBadmin101]

I’m administering a DB plan where the owner has a “proper” 242(b) election in place.

The election states MRDs are to begin the later of (A) termination or (B) attainment of plan’s NRA (65) plus years of life expectancy of table (15).

Would terminating the Plan constitute a revocation of 242(b) and therefore owner must take RMD current age plus make up prior distributions from age 70.5 or can I take position that termination of the Plan is not a revocation of 242(b) election and therefore eligible to rollover to an IRA or new DC plan and begin MRD current age?