3 pages. "[T]he anti-cutback relief should be unconditional for lookback and stability period changes made to conform to the regulations.... [A]ny stability period between the minimum and maximum period should be permitted.... [T]he plan's interest crediting rate should be permitted to be based on the returns on [any] subset [of plan assets], as long as the subset meets the diversification standard.... [The section 401(a)(26) regulations] should be clarified to reflect the recognition in the hybrid plan regulations that a plan's benefits can be based on the return on plan assets, such as by using such return as the plan's interest crediting rate."  MORE >>