HEART Act amendments for DC plans

[Guest AMS_NY]

Is it correct to say that HEART Act plan amendments are NOT necessary for defined contribution plans that have full and immediate vesting because there is no loss of benefits regardless of when/how you die?

Is there citation for this somewhere, either way?

Thanks in advance.

[Guest bobolink]

As far as mandatory HEART provisions go, the fully vested DC plan wouldn't need the death benefit provision but would need the amendment to the 415 defn of comp to include differential pay - unless the employer doesn't pay differential pay.