Cash Balance plan change in mortality table

[AndrewM]

Looking for opinions and code interpretations.

Takeover cash balance plan. Prior actuary was using UP-84 for post-ret AE and CB conversion. TPA taking over administration changed to Applicable Mortality Table. With the new table, the annuity equivalents of the cash balance accounts are lower, which is not unexpected. 

There's some disagreement about whether the change to the annuity value would be a 411 violation. While the annuity equivalent is lower, the plan document defines the accrued benefit as the hypothetical account balance, which is not lower. 

How have others approached this?

[truphao]

not sure if I see a practical issue here.  I am of opinion that you got to protect the annuity benefit but it is extremely likely that the additional one year of pay credits will make the protection to go away.  So, unless you are doing something really funky duiring the very first year after the change, it is a non-issue.  FWIW, I am sure I could be missing something here, so I am interested in hearing other people thoughts.