CB Plan Term & Variable Rate

[Penman2006]

I am working on my first PPA cash balance plan termination. The plan is only 4 years old but the business closed it's doors. The interest crediting rate and actuarial equivalence has always been the 30 year Treasury Rate.

In order to calculate the annuity options, it looks like I have to use the average of the rates used under the plan for the five year period ending on the termination date, is that correct? If so, even though the plan is only four years old would I use a five year average?

[Penman2006]

Maybe I was not specific enough. Section 411(b)(5)(B)(vi)(1) added by PPA says to use this procedure. Any input?

[Effen]

I don't think you are going to get a concrete answer becuase I doubt one exists. I would just suggest you do whatever you think is reasonable and keep good notes and records.

If it were me, and the document said use 5 years, then I would probably use 5 years. The difference between a 4 yr average and a 5 yr average can't be much.