Requirements for eliminating optional forms?

[John A]

Did EGTRRA (or anything else) change the requirements for eliminating optional forms that were spelled out in the final 411(d)(6) regs released about a year ago?

That is, is it still necessary that:

1) after the amendment takes effect for a participant, the alternative payment forms that are still available to the participant must include payment in a single-sum distribution form that is “otherwise identical” to the eliminated or restricted optional form of benefit, and

2) an amendment eliminating or restricting a participant's right to receive payment of accrued benefits under a particular optional form of benefit cannot apply to a participant for any distribution with an annuity starting date that's effective before the earlier of (1) the 90th day after the participant receives a summary that reflects the plan amendment and that satisfies DOL's requirements for an SMM, or (2) the first day of the second plan year following the plan year in which the amendment is adopted?