The District Court for the Southern District of New York has denied a motion for summary judgment on whether participants in PricewaterhouseCoopers cash balance plan properly used certain interest rates in computing lump sum payments. The so called “whipsaw” claim relates to the projection of a hypothetical cash balance account balance to age 65 and then payment of the present value of the projected benefit. Participants had claimed that the use of a 30-year Treasury rate did not accurately reflect the reasonable estimate of future interest credits. The district court refused to accept the opinion of a reputed expert in economics that the use of the risk-free Treasury rate was appropriate because the record had not yet developed and was not complete. (Laurent v. PricewaterhouseCoopers LLP, SDNY 2011)