Does the new NRA rules apply to Money Purchase Sources that were merged into Profit Sharing Plans? Would you need to amend your profit sharing plans that have money purchase sources to change the normal retirement age on that source of money.

Do you allow someone who is still working to receive a distribution from the money purchase source after they reach NRA? If so, I think the answer is that if you have an NRA of 62 or above you are o.k. If it is between 55-62 you have a facts and circumstances test and may want to amend, earlier than 55 you definitely need to amend to to amend.

Where I am not clear is that if you have a mp plan (or mp portion of a ps plan) that for some reason has an NRA lower than 62 but does not allow in-service distributions (or technically post-NRA distribuitons while still working) whether you have anything to worry about.