Actuarial Increase for post-NRD in a frozen plan

[TheBoxMan]

I am working with a frozen plan that is purchasing an annuity contract. The plan NRA is age 65. A participant who termed prior to age 65 is now age 67 and will be part of the contract. The plan wants to pay the same monthly life annuity that the participant would have received at age 65.

Plan does not allow RASD. The plan document does have wording related to suspension of benefits notices, but no one can tell if the notices were mailed out. Plan document states that the deferred retirement benefit cannot be less than the benefit at NRD.

Q1. Do suspension of benefits notices apply to term vested employees? I thought they were only for actively working employees.

Q2. Without a RASD option to give the participant missed payments, plus interest, I think that the payment needs an actuarial increase. Otherwise, the annuity would be "less than the benefit at NRD" because it is being paid 2 years later. Does the annuity need an actuarial increase?

This is my first post, so forgive me if I am missing any details that would help in answering the questions.

Thanks!

[CuseFan]

1. no, you are correct that SoB only applies to actives

2. yes, w/o RASD, you must provide actuarial increase to the NRB