Operational Failure (In-Service Distributions) - Best Way to Fix/

[Guest lizannc]

We have a plan that allows in-service distributions at 59.5 but by lump sum or equal installments (no partials). The sponsor has been allowing in-service distributions to take place paying out partial amounts over the last several years. What is the best way to fix the document. They wish to continue to allow this feature and have not been discriminatory on who may take one (HCs vs NHCs).

[PensionPro]

May be corrected by retroactive plan amendment under EPCRS. Rev Proc 2003-12.

[masteff]

May be corrected by retroactive plan amendment under EPCRS. Rev Proc 2003-12.

2013-12

http://www.irs.gov/pub/irs-drop/rp-13-12.pdf