Spin off and Plan Termination

There are three entities and out of which two of them wishes to continue with the retirement program and hence they decided to spin off their portion into a new plan however the client never got it to our attention or spoke about spinoff.  We went ahead with the termination of the 401k plan and now we are in a situation the term needs to be on HOLD since participants have not received spin off notification letter, looks like some have even taken a distribution any idea from the regulatory stand point how this can be rectified and handle the spin off first. 

Thank you. 

all related CG/ASG entities, or just a multiple employer plan?  That affects some of the consequences obviously....

On 2/17/2023 at 4:08 PM, Bri said:

all related CG/ASG entities, or just a multiple employer plan?  That affects some of the consequences obviously....

The three entities were part of a controlled group.  Company A owned all three entities participating in the 401k plan and the new 401(k) plan will be a multiple employer plan.