Are all past bulk transfers legally valid?

The snappily titled The Occupational, Personal and Stakeholder Pensions (Miscellaneous Amendments) Regulations 2009 provide (among many other things) for connected employer bulk transfers to be made from a formerly contracted out scheme (such as a closed pension scheme) as opposed to only from a currently contracted-out scheme without consent from 6 April 2009. Bit of an arcane point but I wonder how many transfers were made in breach of the old rules - I can think of at least one where the lawyers may have got this wrong. I suspect there are may be others. Would suggest schemes take legal advice to make sure they tie up any loose ends.