in 1998 db transferred assets to dc rather than give distribution options to participants. dc now has annuity options that were in db. to correct is it necessary to do vcp or can we just self correct?

also if we do vcp can we distribut assets to [participants like we were suppose to before vcp approval? thanks

No expert on VCP or Rev. Proc. 2003-44, I'm not sure this transaction would be recognized; the IRS may consider that the DB plan still exists. In this context, does "transfer" mean the same as "merger"?

Need competent ERISA attorney.