Really? Who would ever think that is a good idea...other than the salesperson?
Why would a plan sponsor want to burden themselves with this? Why not just pay a lump sum and if the person really wants a variable annuity, they can buy one outside the plan.
Relius can do it. (ya know, because it's just one interest rate and not segments....) But I *am* surprised not to see any sort of printed-off list at this point with the factors based on interest/mortality required for a 12/31/21 statement. One column for the SLA and one for the QJSA presuming an identically-aged spouse.
I think it's an overpayment under the terms of the plan and should be repaid. I do not see a reason the plan cannot and should not accept a check for $1,000 + earnings as repayment. Just be sure to document everything and make sure whoever is responsible for 1099 reporting has all facts as well.
My understanding is the same as yours that the audit requirement is based upon the BOY count. I think that the 5500 instructions seem pretty clear about that. I don't see any mention affecting the BOY count rule in the event of plan termination. I vote with you Pammie57!