GATT lump sum transition

[Gary]

Prior to GATT, Plan used PBGC rates at time of dist. Plan amended to use GATT as of April prior to plan year. Transition technoque is to use GATT rate as of 2 months prior to dist. (correspond w/ pre GATT timing) and as of April prior to plan year of dist. Whichever rate produces higher benefit.

Say plan was amended 11/1/96 and adopted 8/14/97. If person is to receive lump sum as of say 12/1/96 should it be computed using pre GATT basis, since it was not yet adopted? My undetstanding of law is that you use new GATT technique transition from 11/1/96 through 8/14/98, but how could one use GATT technique prior to adoption of amendment? Any thoughts out there?