Issues with insured takeover DB/DC combo

Cash balance plan with formula something like 10% x YOP for HCES, .5% for NHCES.  Life insurance 100x projected benefit.  Plan names names for eligibility - covers 40% and is amended to add names when needed.

Tested on aggregated basis with PS/K that presumably covers everybody.

What are the issues?  BRF for the life insurance?  Anything else?

Incidental benefit rules? 

Why?  I'm not certain it's 100x.  Let's say it's 50x.

And do you think BRF is an issue for the insurance at 40% coverage?

I think the question is, what is the projected benefit in a cash balance plan, especially if you are using a variable crediting rate.  How do you handle fluctuations in the amount of insurance.  Some years you might have 100X, the next year, the interest rate changes and you now have 120X, or 80X.

And, yes, BRFs are certainly another concern for the same reason.  

There are some good discussions on this board, and also the ACOPA board if you are a member.  In general, I made a decision long ago that insurance inside a cash balance plan was more trouble than it is worth, but then again, that is my general rule for all db plans. 

In my experience, the only reason someone wants insurance inside the plan, is because someone wants to sell some insurance. 

Thanks, no disagreement from me on the wisdom of insurance in a db plan but I have one that I need to deal with unfortunately.  I'll do some searching on the boards including ACOPA.