411(d)(6) and actuarial equivalence

1. Suppose  a traditional defined benefit plan prior to restatement for PPA'06 has actuarial equivalence for optional forms other than lump sums as 7.5% UP84 and for lump sums the greater of 417(e) and 5.5% with applicable mortality. Is it a cutback to restate the Plan with the lump sum now being the greater of 7.5% UP84 and 417(e)?.  If it is a cutback must the AB on the restatement date   merely be maintained and the PVAB at 5.5%/applicable be computed as an additional lump sum  floor on ultimate distribution or does the document also  need to spell this out?

2. Similarly if the AE basis is changed  from 7.5%UP84 to say 5.5% IRS applicable what are the cutback implications for optional forms other than lump sums and early/late ret factors( admin and doc language)?

Thank you for any comments...

1. yes with respect to the accrued benefit.  The document should have some anti-cutback language even if general.

2. You must grandfather the optional form of any benefit using existing actuarial equivalence (or ERF provisions if different) with respect to the current accrued benefit.