plan benefits for distribution upone termination

[Gary]

I'm looking over a plan that intends to termiante and distribute benefits.

4 partiicpants.

facts:

this plan was frozen 12/31/2004.

plan chose to apply pre EGTRRA limits (140k limit in 2002)

fresh start says when plan amended (presumably freeze established fresh start date on 12/31/2004) benefts at that time are fresh start benefits where it is defined as a "frozen accrued benefit" as if employee terminated and such benefit shall be increased in accordance with 415(d) increases if the benefit were subject to 415b limits.

Below is what has been done by tpa:

1. they used 415 $ limit of 140k in 2004 when computing 12/31/04 benefit. Question: should it have been increased by then for COLA to 145k since it was 140k in 2002?

2. benefits that were limited by 415 $ limit did not increase after 2004 for COLAs. Question: should the 415 $ limit have been increased here thus increasing the benefit payable at plan distributionin 2011?

3. benefit that was limited by comp limit was not increased for COLA increases after 2004. Questions: should that limit have been increased for COLA after 2004?

thanks