I would refer her to an agent with a major player (if you know one) like Mass, NML or NYL to review the policy and see what she can do. It might be in her best interest to replace it and do a 1035 exchange if he can pass underwriting. If not, maybe change the investment positions to try and earn at least as much as the interest to keep the DB level on the policy.
Wouldn't the surrender charges start over again? I always mess up these rules.....
Dan