Frozen Cash Balance Plan

A cash balance plan is frozen 6/30 with an estimated distribution date of November 30.  The plan's interest credits were also frozen at 6/30.  Permissible?  Or should interest credits continue through the distribution date.

1. Not permissible
2. If the interest credit rate is a variable rate, the rate of interest used to determine accrued benefits under the plan shall be equal to the average of the rates of interest used under the plan during the 5-year period ending on the termination date

Interest credits needn't be provided except at end of plan year.  If more generous through 6/30 and then no further credit until 12/31 the net impact of November distribution will be copacetic. Document must be followed.

Anything relevant here?

https://hrdailyadvisor.blr.com/2018/06/28/cash-balance-plans-get-irs-guidance-interest-crediting-rates/

("Cash Balance Plans Get More IRS Guidance on Interest Crediting RatesCash Balance Plans Get More IRS Guidance on Interest Crediting RatesCash Balance Plans Get More IRS Guidance on Interest Crediting Rates" -- will be in today's Retirement Plans Newsletter)

depends entirely on the document language. your post states the plan is frozen but not terminated?  how are you making distributions if it is only frozen? note that the five year averaging period on the termination date in the reg examples is the most recent five year crediting periods and not the 60 months ending prior to the termination date. I think it  would be better to use the 60 months with an appropriate time  weighting.