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This might be an opportunity for thepensionmaven to remind the broker that hearing nonsense from fools is among the burdens of being an EX-client.

I'm still trying to figure out how/why access to an investment platform within a plan can be contingent on something, anything outside the plan.

IRC section 4975©(1)(E). If the account minimum is $500,000 and the $100,000 in the self-directed plan account is necessary to achieve the minimum, the plan assets are being used for the person benefit of the participant (who is a fiduciary under the IRC even though not under ERISA) to the extent the account is used for assets that are not the plan assets. This is more obvious when the deal is a fee structure based on assets under management. The investment adviser has a fee scale that steps down as assets increase: 1.0 % for first $500,000, 0.75% for next $500,000, 0.5% for amounts in excess of $1 million. If the manager is willing to aggregate all sources, including the plan assets, then the plan assets may be contributing to acheiving the next step in the fee structure, which reduces the blended rate for all of the assets, including assets that are not in the plan (personal to the participant). If you are skeptical because there is "no harm" to getting a better price than the plan account could have achieved on its own, consider that there are two published PTEs on the subject, but limited to brokers and banks, not the average schmo. Prohibited transactions do not require harm. Perhaps your situation with the brokerage account fits into one of the PTEs.

Thanks Bird! ETA, I recognized by your Good Luck! - I assume you are indeed ERISA Toolkit?

Now that the government has delayed enforcement, it might be a while before anyone figures out an answer to my query.