One option in our plan is a separate account managed by PRIMCO. It is called the "Stable Value Fund".

Is using the word "fund" a problem? Does that imply a mutual fund or can it be a generic term as well?

Is this any problem under Sec 404©?

Your stable value fund sounds like it is a commingled fund managed by PRIMCO, which is quite common. The word "fund" does not imply only a "mutual fund" but does imply that there are many securities (in this case insurance contracts and perhaps other similar contracts) held by the "fund."

Your stable value fund does not have a prospectus. This isn't a problem under ERISA 404© because it requires prospectus distribution only for funds that have a prospectus under federal securities laws. The fund will need to have the same liquidity in terms of how frequently one can transfer in or out of it as your other funds.

Thanks much for your input on this.