I have a plan where an HCE who is terminated has arranged an IRA account that will serve as escrow for the restricted amounts under the plan. If he is below the normal retirement age in the plan is his unrestricted amount the age 65 benefit payable as a straight life annuity (12 payments) or is the age 65 benefit actuarially reduced to his current age?

(1) The unrestricted amount is the life only pension that could otherwise be payable under the terms of the Plan, including early retirement subsidies.

(2) Does the plan provide for an IRA escrow arrangement?

(3) Is the IRA escrow arrangement consistent with PLR 9514028?