Lifetime income disclosures in 2021 or 2022?

Apologies if this has been addressed. If it has, I can't find it.

The interim final rule on lifetime income disclosures specifies that it is effective as of September 18, 2021.

However, both the rule and the original legislation state a variant of the following:

"The requirement in subparagraph (B)(iii)shall apply to pension benefit statements furnished more than 12 months after the latest of the issuance [of]... interim final rules" link

I read this to mean that the first lifetime income disclosure would need to be released at some point within 12 months of September 18, 2021 (i.e., before September 18, 2022).
That is, the first lifetime income disclosure need not be released in 2021, but must occur during 2022, most probably by the Q2/2022 statement, at the latest.

What's the community opinion?

Thanks!   

ERISA § 105(a)(2)(D)(v) states:

The requirement . . . shall apply to pension benefit statements furnished more than 12 months after the latest of the issuance by the Secretary of—

(I) interim final rules under clause (i);

(II) the model disclosure under clause (ii); or

(III) the assumptions under clause (iii).

The interim final rule was published in the Federal Register on September 18, 2020.  The publication covered all three elements.

The rule’s last paragraph [(i)] states both an effective date and an applicability date.

This section shall be effective on the date that is one year after the date of publication of the interim final rule, and shall be applicable to pension benefit statements furnished after such date.

The rule applies to statements furnished after September 18, 2021.

What is less obvious is how that “applicability date” relates to ERISA’s § 105(a)(2)(B), which permits the lifetime-income disclosure “to be included in only one pension benefit statement during any one 12-month period”, even if the administrator must furnish quarter-yearly statements.