DB Plan - IRS DL -- Risk Transfer Language Disclosure

[rocknrolls2]

I am preparing a determination letter request for a defined benefit plan restatement under the third (and last round) of Cycle A.  The IRS website on Employee Plans states that such plans that have risk transfer language need to disclose such language, the location of the language in the Plan document and certain other information.  In this case, the client adopted a lump sum window in 2016 for term vesteds only, so that the Notice 2015-49 restriction and arguably the need to make a specific disclosure in the dl submission would not be required.  I am still inclined to do the disclosure only in hopes of getting a favorable caveat on the point in the ultimate determination letter.  What are other folks doing for these types of windows?