I really thought this would be an easier issue than it's turning out to be, but here are some generic facts for an issue being faced by a few of my clients:

Assume a fully-funded cash balance pension plan is being terminated for the appropriate business reasons. Can the cost of the distribution process only (not the valuation process) be allocated among the individual participants' hyponthetical accounts? I have one TPA who is taking this approach and an unrelated TPA (for an unrelated client) who is questioning this approach.

Does it matter whether the Plan is subject to the PBGC?
Does it matter whether the allocation of cost is pro rata among all partiicipants or in proportion to each participant's hypothetical account balance?

I would appreciate any type of guidance anyone might have.

Does it matter that this is a defined benefit plan?

Apparently it does. So, after some research and critical thinking (often the last of the processes...), it has been agreed to by all of the TPAs that, while this option is available for defined contribution plans, no such corresponding rules are available for defined benefit plans. The main reasons we came up with for this is that there are no actual individual accounts for each participant and that any reduction would probably be considered a violation of 411(d)(6). At the end of the day (formal guidance or not), it's better to be safe than sorry.