I know this may be a stupid question, but I've got "restatement brain"...

I have a 401(k) plan that wants to terminate. No participation, no money, etc. etc.

What notice do I give to the participants saying that they can no longer defer?

Thanks!

Is there any sort of non discretionary benefit stated in the Plan doc: such as fixed Non elective or SHNEC?

Nope, no Safe Harbor or anything. And there are only 2 people deferring, out of almost 20 part's.

Legally, no notice required. Practically, you should give them a warning.