Company A maintains Defined Benefit Plan X. Company B maintains Defined Benefit Plan Y. Company A acquires Company B. Plan Y includes voluntary employee contributions. Company A also maintains Plan K, a qualified cash or deferred arrangement. Company A is considering the transfer of the voluntary contributions of Plan Y (V) into Plan K and then merging Plan Y into Plan X.

1) Is V subject to a separate cash-out rule than the remainder of Plan Y under 411(a)(11) and 417?

(2) Would the transfer of V into Plan K cause Plan Y to be terminated under ERISA Section 4041(e)?

(3) Are there any regulatory filing requirements in connection with the movement of V into Plan K?