In determining whether an individual can be "cashed out" at the $5,000 limit, you must determine whether, at the time of any prior distribution, the individual's accrued benefit exceeded the $5,000 limit. Accordingly, it appears that the lookback rule would not apply to terminated vested participants in a DB plan that have never had a prior distribution. Is this correct? Also, has anyone heard the status of the elimination of the lookback rule?