Restricted Lump Sums and Deferral

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PPA's benefit restrictions (AFTAP <80% but more than 60%) limit the payment of a lump sum to 50% of the value or the PBGC maximum OR the participant is allowed to defer. Presumably the reason to defer would be to give the plan time to come out of restrictions so that the entire lump sum can be distributed.

In the case where a participant elects to defer all or just the restricted portion, how long can the deferral be? Benefits certainly can't be deferred past 70.5 but what about past NRD? It would seem that post NRD the plan would have to provide actuarial increases so as to avoid forfeiture. However not all plans have a provision for AE post NRA currently and instead provide a Suspension of Benefits Notice. In the case of deferral due to PPA restrictions would a Suspension of Benefits Notice provide similar relief? A SOB Notice would seem to be a catch-22 for the participant at NRD who wants a lump sum. Either they have to take the benefit as an annuity or risk forfeiture. The plan could make things even more complicated by permitting a later lump sum of the annuity in pay when and if the plan comes out of restrictions. But there is more than one way to calculate a such a lump sum equivalent and one that would be complicated, for instance, is a 50%JS where the beneficiary has died - is it the PV of what's left or is it something else?

Another deferral related question is what do you think the death benefit is if the participant dies during the period of deferral? Is it just the Pre-retirement death benefit under the plan? Is the answer different if they took the unrestricted part as a lump sum (split the BCD) - are they pre-ret or post-ret?

Has anyone thought of a way to deal with deferrals and NRD/death that is less administratively challenging while maximizing the participant’s options?

Thanks!