PPA Benefit Restrictions

[Guest joe9pension]

PPA and proposed regs provide that benefit restrictions if a plan's AFTAP is less than 80% apply to benefits in excess of "the monthly amount paid under a single life annuity (plus any social security supplements)". Does a Social Secuirty Level Income Option that is elected by the retiree satisfy the exception of "social secuirty supplement"? Can a plan with an AFTAP between 60% and 80% pay this without comparing to the lesser of 50% or the PBGC guarantee?

Related but separate, for the first 3 months of the plan year, before the AFTAP certification is prepared and before the plan is subject to restrictions, can an otherwise restricted benefit where payment is delayed for administrative reasons until after the first 3 months (but the annuity starting date is during the first 3 months) be paid?