Death benefit - subject to anti-cutback rules?

[Guest Sieve]

I'll try this question one more time, a bit more simplified, since there were NO responses to my first post. I'll give up the ghost if I get no responses this time. (I see this as an "optional form of benefit" anti-cutback issue, not an "accrued benefit" anti-cutback issues.)

A DC plan permits a beneficiary to select payment of a death benefit over the beneficiary's life expectancy. (A participant can only select a lump sum at termination of employment.) Plan is restated. Death benefit payout over life expectancy is eliminated, and replaced with a mandatory 5-year payout rule. Ignoring the non-spouse rollover rules that may permit a beneficiary to take a life expectancy payout from an IRA, is either of the following beneficiaries protected against the elimination of the life expectancy payout in the DC plan:

• Beneficiary of a still-living participant (at least as to the benefit accrued by the participant prior to the elimination of the life-expectancy death benefit payout)?
  
• Beneficiary already receiving a life-expectancy payout?
  

(It is interesting to note that the regs prevent the elimination of a protected benefit based simply on the fact that it is payable to a beneficiary. (Reg. Section 1.411(d)-4, Q&A-2(a)(4).) Also, the regs consider death benefits paid AFTER the annuity starting date to be a protectable optional form of benefit in some circumstances, but say nothing about death benefits payable BEFORE the annuity starting date. (Reg. Section 1.411(d)-3(g)(6)(ii)(B).))

[Guest mjb]

I though the cutback rules were revised a few yeas ago to permit certain DC plans to eliminate other forms of benefits as long as the plan allowed a lum sum distribution.

[Guest Sieve]

That's correct if it's a non-412 plan (which my situation is). therefore, are you suggesting that we can eliminate a potential annuity form of payment to the benficiary of a still-living participant since we are retaining a lump-sum option? If so, I think that makes sense. But what about the beneficiary--or participant, for that matter--who is already receiving an annuity form of payment? On what basis, if any, could that be eliminated once it's in pay status--or is it protected now?