Surviving Spouse - QPSA - payout timing

[Guest ebailey]

I have a DB Plan which currently states that Surviving Spouse gets QPSA on the first day of the month following death of Participant. The actuaries hate this and want the payment to begin "upon application" by the Surviving Spouse. Is there anything that would NOT allow me to amend the plan to allow for the payment to begin upon application (date of Surviving Spouse's choice) as long as I limit it as follows:

- must be allowed to commence no later than month in which participant would have attained earliest retirement age (1.401(a)-20 Q&A 22(a).

- must begin no later than the later of 12/31 of the year following P's death or 12/31 of year in which P would have been 70 1/2.

Any insight would be appreciated.

Thanks

[Andy the Actuary]

I have a DB Plan which currently states that Surviving Spouse gets QPSA on the first day of the month following death of Participant. The actuaries hate this

Since when did the inmates start running the asylum???

Don't know the answer but suggest checking the regs. under 411(d)(6) or asking the attorney the actuaries also hate.