Frozen Cash Balance Plan

[cohendrake]

This is a church plan so maybe this works but I have my doubts:

A) Monthly benefit defined as NRA Cash Balance Account divided by a annuity factor based on 417(e) mortality table and

30-year Treasury rate @ first day of year of retirement

B) Benefit accruals frozen as of 1/1/2007

C) As 30-year Treasury rates tumbled recently (and for 2009) the annuity factor rose and monthly benefits dropped so that

someone retiring at age 65 would get a monthly benefit about 15% lower if they retired now (or in 2009) than they would

have had they retired in any other year since the freeze.

Any problems?