412i conversion

[FAPInJax]

A client is converting a 412i plan back to a regular DB plan. The primary issue appears to be that the PPA valuation reflects 100% lump sums. However, the proposed regulation method which uses the interest segments and the plan PVAB are producing a funding target less than the current lump sums in the policies. Is it acceptable to set the funding target equal to the grandfathered lump sums (knowing these are not moving and will disappear over a period of years)??

This could also create the problem where although there are benefits accruing that the normal cost is zero because the minimum lump sums have not been reached.