Have a handful of 412i plans that now are "converting" to traditional DB plans but keeping some of the insurance policies (policies become part of the assets; envelope funding used).
In my way of thinking the benefit formula is unchanged so that there should not be any 411(d)(6) issues with the accrued benefit since it would be as defined under the plan document which hasn't changed. Howver, my opposing thought is when it was a 412i the accrued benefit was equal to the contract value. Does this contract value have to be preserved at a minimum for each participant in the 412i plan ? Kind of a de minimus benefit until new accruals (if any) surpass it ?
Thoughts ? Thanks.