"The PBGC ... would treat these amounts as covered in priority category two (PC2) ... [which] means that the benefits would have a higher claim on plan assets than most benefits owed under a terminated pension plan. However, unlike other PC2 benefits, the PBGC generally will not pay out any benefits attributable to a rollover as a lump sum and, for purposes of preretirement death benefits, the PBGC will include those benefits in the value of the plan's qualified preretirement survivor annuity for the surviving spouse of a deceased participant. Significantly, this special treatment will only apply to rollovers that are treated as mandatory employee contributions for purposes of Section 411 of the federal tax code."