Profit Sharing Plan with excess asset provision ( FIS)

We're drafting cycle 3 docs for a PSPs receiving excess assets from terminated DB Plan. Under FIS the plan provides that excess assets from a terminated DB can be transferred over. Does this require the distribution options to include J&S provisions? These PSPs  previously paid out lump sum only.  The J&S provisions would be required if Money Purchase Plan assets were being transferred or merged, but I don't believe it is required for excess assets from a terminated pension plan. Is this correct?

I don't think so either.  Those funds didn't belong to anyone, everyone in the DB was fully funded.  Therefore, there is no spouse to attached those funds to.

Glad you agree, sound reasoning.