Regarding testing a cash-balance plan using general test (on benefits basis). If your plan's actuarial equiv. interest rate is something close to 30-yr bond rate, is "normalizing" needed from plan actuarial equiv. to standard mortality and interest rates for NAR purposes ?

What if the cash-balance plan allowed for lump sums, under current interst rate environment would you likely have a MVAR greater than the NAR due to 417(e) subsidy ?