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A self directed DB plan - not a good idea. You can give market rate earnings in a CB plan, but considering the minimums required, floors on the hypothetical account balances and such stuff, not a good idea even if legal.

Current plan document language will probably address whether you use the plan's entry date or the statutory semi-annual entry dates. Our PPA VS document says you use semi-annual entry dates. If you look at an older document, it likely won't address it. The IRS speaker's 2006 comment was basically that you had to use the plan's entry date, unless the plan language said you use something else. The ASPPA panelist's reply was that if we had known we needed to put that in our documents, it would be in there.

Let us know how the "invasion" goes!

1 is too few, 13 million is too many. So somewhere in between. Like jpod I don't thing there i any direct guidance on the optimal number of investments. It is left to the prudence of the Trustee's to decide.

Aside from the fact that it is generally understood that ERISA embraces the concept of "modern portfolio theory," whatever that means, my guess is that there is no guidance other than perhaps one or more reported cases where the courts found - based on the particular facts of those cases - a lack of diversification consistent with the ERISA diversification standard.

Based upon my experiences with the DOL I support the opinion of rcline46. The DOL folks are comically undertrained, uninformed etc. but with potentially frightening power.

Unless the CPA is also an attorney, it's time to get a real attorney involved.