or a qualified plan distribution annuity contract (as defined in section 401(a)(38)(B)(iv)). . (e) Effective date The amendments made by this section shall apply to plan years beginning after December 31, 2019. 107. Treatment of custodial accounts on termination of section 403(b) plans Not later than six months after the date of enactment of this Act, the Secretary of the Treasury shall issue guidance to provide that, if an employer terminates the plan under which amounts are contributed to a custodial account under subparagraph (A) of section 403(b)(7), the plan administrator or custodian may distribute an individual custodial account in kind to a participant or beneficiary of the plan and the distributed custodial account shall be maintained by the custodian on a tax-deferred basis as a section 403(b)(7) custodial account, similar to the treatment of fully-paid individual annuity contracts under Revenue Ruling 2011–7, until amounts are actually paid to the participant or beneficiary. The guidance shall provide further (i) that the section 403(b)(7) status of the distributed custodial account is generally maintained if the custodial account thereafter adheres to the requirements of section 403(b) that are in effect at the time of the distribution of the account and (ii) that a custodial account would not be considered distributed to the participant or beneficiary if the employer has any material retained rights under the account (but the employer would not be treated as retaining material rights simply because the custodial account was originally opened under a group contract). 108. Clarification of retirement income account rules relating to church-controlled organizations (a) In general Section 403(b)(9)(B) is amended by inserting (including an employee described in section 414(e)(3)(B)) after employee described in paragraph (1) . (b) Effective date The amendment made by this section shall apply to years beginning before, on, or after the date of the enactment of this Act. 109. Increase in 10 percent cap for