Changing a PPA Amendment

[Susan S.]

A 401(k) plan allows in-service distribution of deferrals, match, and PS accounts at age 59 1/2. Several participants have money that was transferred from the employer's terminated pension plan. The transferred assets are not eligible for in-service distributions. The PPA amendment specified that in-service distributions of transferred pension assets would not be allowed at age 62.

The employer wants to amend to allow in-service distributions of the former pension accounts at age 62, leaving the other accounts as-is, eligible to be distributed at 59 1/2.

Document is Sungard Corbel. How do I change the PPA amendment? Do I call it a revised amendment?

Looking at the document checklist and language manual, even if I had originally coded for distributions at age 62, it doesn't look like this would have been mentioned anywhere except the PPA amendment. Do I need to amend any other section of the document, such as adding it to the "In-Service Distribution of Employer Contributions" section?

[John Feldt ERPA CPC QPA]

You can submit an incident to SunGard, I'm sure they will help you.

Perhaps the "describe" line of the in-service section could have the age 62 restrictive language. It could say the age 62 restriction only applies to former pension accounts - I think that same language you place their will show up in the SPD unless you use a language override.

[BG5150]

Can't you just do a garden variety amendment to allow it?