I have not seen much helpful guidance out there on this provision. The Code and the proposed regulations state that the plan must include a provision dealing with the special interest rate rules that apply in the event of termination. However, I don't know whether the IRS is expecting anything to be placed in the plan other than the basic rule, or if it is okay to just incorporate the Code and regulatory provisions by reference. For purposes of new plans or those being amended and restated this year, does anyone have any sample langauge that they are proud of and would like to share, given that this does not seem to be a matter for which any model language will be provided by the IRS?