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Is this (see attached screenshot) what it looks like to you now? If you click on the icon that's circled in red in the screen shot (the side that's not already black), do you get the view that you prefer?

It's only a problem if participants were paid out at less than 100%. Do we know that?

I'm pretty sure I wrote that ASPPA proposed answer to the question and we know that the IRS agreed. The participant had a hardship distribution when the distribution was made and at the time of being made, it met all the criteria. The fact that the deal fell through doesn't change the circumstances of the distribution or the tax ramifications. The rules are written to allow these distributions and a valid purchase/sale agreement is all that is necessary to justify it. If the deal ultimately doesn't happen, well that is just life and there is no going back.

If you go to page 51, it uses 401(k) type plans rather than all DC plans. The percentages here are probably more in line with what is expected 8.7% (46,696 / 533,769) are trustee directed 2.7% (14,403 / 533,769) offer limited participant direction (probably on the 401(k) portion) 88.6% (472,669 / 533,769) are participant directed 79% of the trustee directed 401(k) plans have less than 25 participant

Note this isn't just 401(k) plans this is all DC plans. So this would include ESOPs which almost never have anything other then trustee directed. There are a few KSOPs and a very rare ESOP that allows for participant direction of their diversification accounts inside an ESOP. Going back to my days when I did balance forward DC plans and ESOP (2009 was the last year) my experience is very few 401(k)s don't allow some kind of direction. Even the balance forward PSP and 4ks we had still allowed quarterly or monthly changes. Primary reason we had any PSPs or 4k plans that were balance forward was becasue the sponsor wanted something about that plan's running the large plateforms wouldn't give them. They had favored investment advisors or some servce our practice was willing to give them if they paid us for the service. We weren't the cheapest TPA by a long shot but we pretty much gave you what you wanted. For example: We had a client that had favored investment advisors. They wanted us to give them monthly reconciliation and earnings allocations that included specific guidelines on the ROI for the advisors within days of the statements coming out. If the advisors missed the agreed upon ROI benchmark too many times they were replaced. On the annual statements it included a life to date break down of the companies PSP contributions by year. For some people it went back to the late '60s. This had a total so the person could see how much of their account was company money vs earnings. They put in a near maximum PS contribution every year for their people. They paid us great money for those services and were happy as can be.