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un-terminating a plan?


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we have a regular 401(k) plan that terminated as of 11/15/2013. passed out notices, stopped deferrals, signed the amendment, etc. Most participants have already returned their distribution forms.

We anticipated distributions to start shortly, with assets out by 12/31/2013 and 2013 being the final year.

The plan sponsor now has changed their mind about terminating the plan. Other than the participants being 100% vested,I don't see an issue. I think the plan sponsor would need to get new deferral elections because the notice given indicated that all salary deferrals were going to cease as of 11/15/2013.

What I don't know is about distributions. We are after 11/15/2013 and participants have accrued a distributable event. The fact that no one has actually been paid out doesn't change the fact that participants have a right to take a distribution, and undoing the termination would presumably take away that right.

I seem to think there were several threads on this topic already, but I can't seem to find them.

What if they terminate the plan and then start another? I would think the successor plan rules would dictate that the participants didn't really have a distributable event, yes? or would the new plan just be disqualified?

If anyone can point me in the right direction I would appreciate it.

I'm a stranger on the internet. Nothing I write is tax or legal advice. 

I'd like a witty saying here, but I don't have any. When in doubt, what does the plan document say?

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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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