Final 411(d)(6) Regs - Requirement to offer a deferred annuity on plan

[Guest Gibson]

Do the final regulations impact the requirement to offer a deferred annuity on plan termination? We have a money purchase pension plan. Amended 1.411(d)-4, A-2(a)(3)(ii) seems to say that you can substitute cash payments for annuity contracts, provided the cash payments are identical to the annuity contract except for the source of the payment. What does this mean for a terminating plan?