cash balance accrued benefit at NRA

For purposes of computing the equivalent accrued benefit at NRA in a cash balance plan, can the benefit decrease at a later point in time due to a decline in the projected interest crediting rate?  Practically it will likely not matter since a participant will opt for the cash balance account value.  There is no early retirement date in this plan for what it is worth. I would think it could decline,but not sure if the IRS has ever opined on this. The 411 regs were written with traditional defined benefit plans in mind so not much guidance there.

I don't think the accrued benefit can ever be less than the highest it is on or after early retirement eligibility. That the plan does not have an early retirement provision is the key, I think, and allows the accrued benefit to fluctuate up and down with the interest crediting rate and resulting projection. Yes, in reality it won't matter because benefit will be paid as a lump sum, but we all know practicality and IRS rules do not mix!

Reason #27 on the Big List of Reasons Why You Shouldn't Use a Variable Interest Crediting Rate.

Thanks CF and C.B. for your comments. I think Cf that is definitely true for traditional dbs but was not sure if the consensus was that it mapped over to the NRA equivalent for CB plans.  That is a good point CB for a fixed crediting rate;my impression has been that in recent years, at least since the 2014 regs, that most actuaries were leaning toward variable rates.  I think using the segment rates can eliminate funding whipsaw but may well invite the problem I have raised here.

51 minutes ago, Draper55 said:

since the 2014 regs, that most actuaries were leaning toward variable rates. 

Interesting comment.  I would not have said that, but that might just mean I am out of touch.  Hard to say what "most" are doing when there are only limited opportunities to network due to COVID.  I agree that larger variable plans are becoming more popular, but I haven't seen that thinking invade small plan land.