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I definirely knew the statement would be straightforward but even still was hoping to plagiarize something! Thanks for the clarification! I think WDIK once said, in response to an accusation that common sense was not employed in the drafting of regulations: "It's not that no sense was used in drafting regulations; it's that the sense used was not common." Found it! It was 13 years ago! It's my all time favorite quote on benefitslink; and for the record, I'm almost certain that I would not have such a thing if it were not for this quote. "Certainly there was sense involved during the creation of regulations such as this. It is just that those individuals involved in the process are of such elite caliber that the sense used is not common."

People have been using prime +1 without consequence (that I know of) for years now.

Participants will need to be provided at least 30 days in advance with an updated fee disclosure that explains the fees which may be charged against their account.

Is the plan participant directed? Are you looking to take fees from forfeiture or from participant accounts? Did the participant fee disclosure state that TPA fees might be paid from their accounts?

Broadly speaking (i.e. not to get into asset class/composition specifics), lot to be said for using a core or more of balanced and/or tactically managed funds. Like potato chips, one might not be enough except for smallest plans, and even then...Alternatively a traditional 60:40 portfolio provides generally the same structure but with more control of underlying holdings. Maybe further overweight equities if employees can take in-service withdrawals beginning at or around normal retirement age. Maybe underweight equities somewhat if average age is particularly high.

In addition to all of the above my two cents worth is that the investment fiduciary will need to be sensitive to the plan's liquidity needs as participants retire. Looking ahead to who accounts for how much of the plan assets and forecasting when they are likely to want to be paid is important.