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Posted

Can a plan that currently allows for immediate distribution (upon termination of employment) be amended to allow distributions only in the plan year following termination of employment without violating the anti-cutback?

QPA, QKA

Posted

If the plan is subject to IRC 411d6, that would appear to be an impermissible cutback. Is that how you read 411d6?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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