Plan Termination Distribution Election Form maintained on file

Defined Contribution Plan is in termination stage.  IRS Form 5310 has been submitted and the Plan is waiting for IRS determination letter. The Plan Administrator wants to wait for the favorable determination letter prior to processing distributions.

However, the Plan Administrator would like to mail out distribution election forms for the Participants to complete sooner than later.  How long can the administrator hold the completed distribution election forms on file prior to processing?

Is it 180 days?

For example, if the Plan Administrator receives completed distribution election forms and maintains them on file and the IRS determination letter arrives 7 months after receipt of the forms, would that require new election forms to be obtained.

Yes... as far as I know, the distribution election form is only good for 180 days after execution.

Isn't the 180 days technically measured from the date the participant gets the 402(f) notice?

Correct, person cannot get 402(f) notice more than 180 days before the annuity starting date, which in this case I think would be the distribution date. I don't know how quickly a DCP termination d-letter happens these days, DBPs usually take 9-12 months. I think they can't issue a letter any sooner than 145 days, so maybe send out forms after four months (120 days). Unless the plan is an ESOP, part ESOP, or has some crazy provisions, I would think you'd have d-letter in time to be within those 180 days. Just a thought.