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IRS Bans Lump Sums to Already-Retired Pension Participants
October Three Consulting Link to more items from this source
[Guidance Overview]
July 24, 2015

"While the general thrust of the change in policy is clear, the Notice is relatively brief and leaves several questions un-answered. May lump sums be offered to retirees under age 70-1/2 (the 401(a)(9) 'required beginning date)? It looks like the answer to this question will be 'no.' May lump sums be offered to retirees in connection with a plan termination? It looks like the answer to this question will be 'yes.' But we will have to wait for the actual proposal of a regulation (at least) before we get definitive answers to these questions."

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