QJSA Requirements

[Guest kowen]

Assume that a defined contribution plan is subject to the QPSA/QJSA requirements and that a portion of contributions is used to purchase term life insurance. Are the life insurance proceeds also subject to the QPSA/QJSA requirements, or just the accumulated account balance? If so, would the normal form of payment of the life insurance to the survivng spouse be an annuity? The plan document identifies the insurance as part of the death benefit payable under the plan. Plan sponsors and administrators I've spoken to seem to think the insurance proceeds are subject to joint and survivor requirements, while others in the insurance industry say that 100% of the proceeds would go the designated beneficiary whether the participant was married or not.