My reading of Rev Rulings 98-30 and 2000-8
is that , notwithstanding the annual notices distributed
by the plans in the fact patterns, the IRS (as reflected in the LAW and Analysis part of the rulings) only requires "a notice," i.e., the
initial notice to the participant prior to the initiation of payroll
deductions.
Does anyone agree or disagree? Is there any more recent guidance?