ISW delayed, now maybe the EE will terminate?

[AlbanyConsultant]

I've got a small pooled PS only plan.  Participant R, who is a 10% owner, has about 80% of the money in the plan.  She has had a medical setback and requested an in-service withdrawal to be paid as soon as possible; she completed the proper form and submitted it.  I advised that the Plan Administrator should consider running an interim valuation, given that the assets are up ~20% year-to-date, and that's when I found out that there is currently a changeover in ownership and management and everything.  So it's been almost two weeks as the other/remaining/new top people argue amongst themselves who will be the Plan Administrator and who will be Trustee and who will get to make this decision, and R has been waiting patiently.

R called to ask where her money is, and noted that she might be separating from service soon.  That triggered an alarm, because terminated participants are eligible to receive a distribution only after the end of the year of termination (to allow for the allocation of gains/losses during the year).  So... if she does terminate while these people are still dithering about who should authorize what, or even if they get their acts together and authorize the interim valuation and she terminates while we're in the process of doing the interim valuation, would you think that invalidates her in-service request?  I don't think so, since she made the request in good faith while she was an active participant, and it was only due to the... well, call it what you will of the people around her that caused it to not get paid timely.

[Mike Preston]

It does Not invalidate the request. 

[Peter Gulia]

Does the plan's governing document mandate an interim valuation, or rather allow an interim valuation?

What amount or portion of her account did the participant ask for?

If 100% (and whether to use an interim valuation is discretionary), does the participant run a risk that the plan's fiduciaries approve her claim but use the December 31, 2018 valuation?