With the temporary window afforded by the lapsing of PFEA, one of my clients is questioning whether it would be smart to amend his plan to provide for a fully subsidized Early Retirment Benefit at his current age of 54. His accrued benefit is equal to 100% of high 3-year average compensation but is significantly less than the IRC 415 dollar limit at age 54.

If we make this change, am I correct that his maximum lump sum would be based on the APR using 30-year treasury rates and 94GAR at age 54?

If he can afford to make the payment now, and he is not looking for future db deductions, this looks like a good time. But do it quick, because you need amendment time, 7 day notice time, and time to complete the rollover to an IRA. You are betting that Congress won't act first.