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A question is raised regarding the impact of an increase in the 415 limits for a frozen plan. Situation is as follows: Sole Prop pension plan, 10% per year of service formula. At 12/31/18, participant has 6 years of participation and 18 years of service. Comp is $160,000 and accrued benefit is $11,000 per month ( eg 60% x $220,000 dollar limit). The plan is frozen 3-15-2019 before accruing 1,000 hours. The 2019 415 limit is increased from $220,000 to $225,000. The question is what is the benefit used for the FT for 2019? The regs under 430 state that the FT is based on the benefit that has been accrued, earned or otherwise allocated to yrs of service prior to the first day of the plan year. The regs further say that the TNC is based on the benefit that has been accrued, earned or allocated to service from the 1st day of the plan through the val date, which in this case would be the freeze date. The regs are silent with regard to the impact of 415 changes in the dollar limitation. My interpretation is the benefit for the FT is $11,250, e.g. increase in the dollar limit goes to the FT. Any opinions?