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Or the plan simply says NRA = 65 without a years of participation requirement. And, correct me if I'm wrong, but I think participants have to be employed at NRA to get full vesting; i.e. they can't simply delay the distribution and become vested when they reach NRA if not employed. Anyway, I see the idea of changing NRA to be more in line with SSRA to be a non-starter.

There are always concerns when 412(e) is involved. Assuming the policy fully provides for the plan's benefit, from a qualification aspect the plan might be OK, but refer back to my first sentence above. The excess premium payments (aka contributions) might not be deductible. Furthermore, if the plan already provides for a benefit at the 415 limit, then there's no place for the money to go (refer back to my first sentence above). In 2004 IRS came out with all sorts of bad news for abuses in fully insured plans, up to and including "listed transactions" for buying insurance in excess of the plan benefits. I am not an expert in listed transactions and have no idea if this would apply here, refer to ERISA counsel and of course, refer back to my first sentence above.