PBGC Premium calculations for cash balance plans

[AndyH]

If a cash balance plan has a variable interest crediting rate or has changed from a fixed to a variable rate, is it required that accrued benefits be valued for purposes of computing annual PBGC premium liabilities by projecting account balances to ARA using an average of the last 5 years of crediting rates? Opinions please.

[SoCalActuary]

My understanding is that you use the current interest crediting rate unless the plan is terminating.

[AndyH]

Thanks. I don't see anything in the PBGC instructions that directly conflicts with this, but it seems open to argument from them if they choose to do so.