A pension plan terminated and all assets were distributed. Two years later, it was determined that some additional amounts were due to a number of participants.

Should new elections be obtained from all affected participants, only those whose total distributions exceeded $5,000, only those whose additional distributions exceeded $5,000, or some other option?

The lookback rule for determining certain consent requirements was eliminated a bit ago, so the focus is now on current distribution amounts. If they are over $200, they need rollover election forms. If over $5,000, then they need consent forms as well.