Eliminating Optional Forms of Benefit when QJSA Required

[Guest GraceWoodbury]

We would like to eliminate all QJSA options but one in defined contribution plans that require the QJSA option. 1.411(d)-4 Q&A 2(e) was effective January 25, 2005 and seems to indicate that all optional forms of benefit can be eliminated as long as a lump sum option is retained (our plans are otherwise required to keep at least one QJSA option). However, 1.411(d)-4 Q&A 2(b)(2)(ii) is specific to QJSAs and states that a plan with 3 or more QJSA options may be amended to eliminate any of them, as long as the smallest and largest are retained. Any thoughts regarding if we have to keep the smallest and the largest, or does the new 2(e) allow us to eliminate all but one QJSA option?