Permissive service credit purchase and 415

[MGB]

What is everyone's opinion on whether the 415 limit rules of 415(n) apply to permissive service credit purchases in a DB plan under a trustee-to-trustee transfer from a 457 or 403(B) plan?

The language under EGTRRA amending 403(B) and 457 only refers to the definition under 415(n)(3). The link to the limitation application in 415(n)(1) does not seem to be there.

So, in a transfer, are these amounts subject to 415 limits or not? Does anyone know of another reference on the issue?

[MGB]

I did find a reference in the 457 proposed regulations.

Under 1.457-10(B)(4)(iii), the example "facts" are that the transfer would be subject to 415.

The issue is that this is just the facts of the example. They don't actually come out and say that all transfers must be subject to 415. However, why would they include it in the set up to the example if it wasn't a pertinent issue in the facts?