To whom must notices be provided when benefits are restricted?
It appears a fundamentalist reading of the proposed regulations would suggest everyone. And while this may be the correct answer, it can produce a totally ludicrous and unncessary result.
Certainly, why would you notify participants whose benefits are in pay status, or for that matter active or terminated vested deferred participants who are not eligible for payments during the period to who the restrictions would apply?
Is there guidance of which this actuary is unaware?