excluding terms invested in insurance contracts

[austin3515]

Instructions to line 6 of the Form 5500:

2. Retired or separated participants receiving benefits (i.e., individuals who are retired or separated from employment covered by the plan and who are receiving benefits under the plan). This does not include any individual to whom an insurance company has made an irrevocable commitment to pay all the benefits to which the individual is entitled under the plan.

Anyone see a problem with applying this to a defined contribution plan funded with insurance contracts exclusively (i.e., no Trust).