Under Rev Proc 2000-40 Sec 4.02, can one chg only the val date to the termination date, w/o changing the funding method to unit credit? My reading seems to indicate it is not allowed under the Rev Proc, but I want it to be so.

You are correct. Why do you want it to be so?

EOY val date, and staying with IA funding method, would just be easier and more straightforward. Sole participant at NRA is terminating plan and wants to fund the plan up to the maximum lump-sum limit. Assets are in cash, so we know plan won't be overfunded with asset fluctuations. EOY val date with ctb made in early January would get the result desired. In any event, I worked around it. Thanks for the reply.