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FBRIC determination

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I am having general trouble understanding the third criteria of FBRIC determination.

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The contract requires all participant-initiated transactions to occur at contract value (without any conditions, limits, or restrictions).

The contract will say something like below:

Transfers from Fixed Account Plus. The Participant may transfer up to 20% of the Accumulation Value allocated to Fixed Account Plus during each Certificate Year.

Is that a limitation that would violate the criteria of fully benefit responsive investment contracts?

As an additional question, are there any good CPE's or just websites or videos with in depth explanation of the investment vehicles we see in these plans (GICs, PSAs, etc.)?

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I assumed that requiring the benefit to be at contract value would be "conditioned, limited or restricted" if the value of the asset dispersed from investment was different (less than) than the value of the investment while it was still held for investment. For example a term such as you must hold onto this investment for 24 months otherwise you get paid out 99.5% of the contract value.

So I would think the 20% annual transfer of accumulation value in this case would not be a condition, limit or a restriction because the assets held for investment will always equal the amounts disbursed upon the election of the participants. 

I could be wrong.

CPE for retirement related topics always pop up in the spring. I would check the AICPA or your state's CPA society to see if they offer anything along these lines.

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