Bankruptcy as COBRA QE for retiree plan that is alternative coverage.

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Cost and coverage under employer's retiree plan is different than cost and coverage for active employees. Because retiree plan is technically "alternative coverage," retiree (and spouse, as applicable) are given choice between COBRA under the active employee plan and enrollment in the retiree plan.

I know that the retiree's spouse must be offered COBRA under the retiree plan if the spouse loses coverage under the retiree plan because of legal separation, divorce, employee's death, or employer's bankruptcy, per the Treasury Regs (54.4980B-7, Q&A 7©).

But is the employer's bankruptcy a QE for the retiree who elects alternative coverage under the retiree plan? The general rule under the Reg is that "if an individual rejects COBRA continuation coverage in favor of alternative coverage, then, at the expiration of the alternative coverage period, the individual need not be offered a COBRA election" (Reg 54.4980B-7, Q&A 7©). However, "a proceeding in bankruptcy under Title 11 of the US Code with respect to an employer from whose employment a covered employee retired at any time" is a QE (Reg 54.4980B-4, Q&A 1(b)(6)).

Does the "bankruptcy as QE" rule supersede the retiree coverage's status as alternative coverage, so that bankruptcy is still a QE for ANY retiree coverage? Or is the loss of coverage by the retiree due to bankruptcy the "expiration of the alternative coverage period," so that COBRA need not be offered to the retiree under the retiree plan?