1.401(a)(4)-5(b) restrictions & church plans

[Guest]

Do the restricted participant distribution rules of

1.401(a)4-5(B) apply to church plans?

I have a new church plan client (db) which is currently

underfunded and the only HCE would like to take a lump

sum. Based on my reading of the regulations, I think these

provisions apply to church plan, but I'm not positive. Has

anyone ever faced this?

He was not real happy when I brought this up

[Guest]

If anyone cares, I now am pretty confident that it does apply.