New ERISA 101(m), as added by PPA, is generally effective for plan years beginning after 2006. but has a transition rule that is confusing me. The transition rule provides that, if notice would otherwise be required before the 90th day after enactment of PPA, then the notice need not be provided before the 90th day.

For a calendar year plan, does the transition rule override the general effective date and require notice to be given by 12/2/2006?

Note: I also posted this message on the ESOP board.