Does a blackout notice need to specifically use the word "blackout"?

[Florida401k]

I am working with an new administrator on moving plan assets and the blackout notice they provided to the affected participants does not specifically use the word "blackout". Rather, it uses the language "No Transaction Period" interchanged where the word "blackout" would be generally used. The notice contains all the other necessary language and dates, but I've just never seen a notice that doesn't use the word "blackout" to describe the period.

Is this allowed under IRS & DOL regulations?

Thanks

[My 2 cents]

Don't know, but wouldn't the requirement be to communicate that there is a period during which no changes can be made to the account, without regard to the specific words that are used? Requiring the use of "blackout" without also requiring a more detailed explanation makes as little sense as treating a suitable description of the period during which investment changes cannot be made, without also saying "blackout", as defective.

[Peter Gulia]

Under the rule (29 C.F.R. § 2520.101-3), the notice must include the required information and “be written in a manner calculated to be understood by the average plan participant[.]”

It’s possible to do so without using the word “blackout”.

The rule itself defines “blackout period” as a period in which a participant, beneficiary, or alternate payee is temporarily restrained from doing something one could do in the plan’s ordinary administration.

So translating “blackout period” as “no-transaction period” might, if it’s factually sound in the plan’s circumstances, be a sensible label (assuming the notice also includes the required information).

[My 2 cents]

I suspect that the issue arises because the sponsor just does not want to use the word "blackout".