Distribution During Plan Termination

[Pension RC]

I'm involved in a PBGC plan termination. A terminated participant would like to receive a lump sum, which is allowed under the plan. However, the participant notices have been distributed and the Form 500 was recently submitted. The participant would like, if possible, not to have to wait until the end of the 60-day review period. My reading of the Form 500 instructions is that this is fine since it is a terminated participant. Am I reading this correctly?

Thanks for any responses!

[My 2 cents]

If the participant, but for the plan termination, would be eligible to elect an immediate lump sum under the normal operation of the plan, it is my understanding that it would be acceptable to make that payment (assuming, of course, that there are no Section 436 issues or top-25 issues with making such a payment). It is my understanding that this is NOT true with respect to the purchase of annuities.