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I observe that if the client has no clue where to find a resource on which to base their investment decisions, they should not be making any investment decisions for the plan. You may want to point the client to articles about their fiduciary responsibilities and the risk they are taking by doing a task for which they are not qualified to do. Here is an example: https://www.employeefiduciary.com/blog/meeting-401k-fiduciary-responsibility Good luck!

As @Bill Presson noted, plan accounting for SDBAs for individual participants existed many years before than daily valuations applied across the entire plan. The plan accounting methods used for those SDBAs are fully compliant with all requirements for any defined contribution plans. Note that there are multiple approaches to the accounting techniques so the math may differ, and the results may vary slightly, but all are compliant. This also happens to be true about daily valuations. Not all recordkeepers use exactly the same plan accounting math and the results do vary slightly, but each recordkeepers' results are compliant. There are many variables that come into play. Some are related to plan design like, as @Gadgetfreak notes, includes vesting, administrative fees, Roth tax basis, investment in contract from other already taxed amounts, prior partial distributions, and loan accounting to name a few. Others are related to the type of investment that may be permitted in the SDBA like employer securities, limited partnerships, private placements, periodically valued investments, certificates of deposit, non-benefit responsive GICs and gold bullion to name a few. There also may be a need to accommodate securities that will only trade in whole shares. I have seen and done plan accounting for all of the above, and all of that plan accounting is and was fully compliant. Timing of transactions is not an issue. Distributions from fully or partially vested sources, could be made daily (if the assets were liquid). Practically, SDBAs that have several complicating features require can require individual attention and that comes at a cost, and the plan can have that cost paid by the participant's SDBA. That added cost should factor into the plan sponsor's decision whether to have SDBA's and, if allowed, whether there will be restrictions placed on the sources that can be in the SDBA and the types of investments that can be held in the SDBA. As an industry, we all are obsessed with being 100% accurate, but what we really are obsessed with is being 100% compliant. An the often unrecognized beauty of the laws and regulations that govern the plans we work is the flexibility to creatively design and recordkeep a plan that meets the objectives of the plan sponsor.

A long time ago, I had several SDBA only plans with 100+ accounts... I could swim in monthly statements like Scrooge McDuck when I did the year-end work. I don't miss those days. At my current firm we are daily val and only allow SDBAs from our RK platform. All the activity rolls up to our trust statement so it really doesn't matter how many SDBAs are in a plan.

Wow. That seems like a lot of work. SDBAs have daily access, and someone could potentially request a distribution at any time. Vesting needs to be updated—as do sources—before that happens. If deferrals are being deposited on an ongoing basis, wouldn't you need to track each payroll for each SDBA often? With pricing coming down and providers offering flexible billing options, I suspect a daily platform would be more cost-effective than a TPA doing all that.

There shouldn't be a legal impediment to merging the Plans (if there is a coverage issue, the client may need to enter VCP to resolve). Presumably, B and C are going to enter into a PEO agreement with the existing PEO; otherwise, I don't see them permitting the merger. Note that it is the PEO plan that will be merged into so you will need to seek their approval and will likely to coordinate with them along with the other recordkeeper(s)/administrator(s).

I practice law in Maryland and DC and specialize in preparing QDROs intended to divide pension and retirement benefits for divorcing spouses. I have prepared such Orders for the District of Columbia Police Officers and Firefighters’ Retirement Plan. See the attached Summary Plan Description for that Plan. Another document dealing with D.C. SPOUSE EQUITY ACT INFORMATION STATEMENT THE DISTRICT OF COLUMBIA POLICE OFFICERS AND FIREFIGHTERS’ RETIREMENT PLAN is also attached. Normally if an employee retires while still married, the spouse at that time will be entitled to receive survivor annuity benefits at the time of his death. But that doesn't look like your situation. If you were divorced in 2016 and the Court did not enter a "Qualifying Court Order" in connection with the divorce awarding you retirement and survivor benefits, then you did not receive a share of his retirement benefits from and after 2020 when he retired, and you will not receive a survivor annuity now that he has died in 2023. If you had a lawyer representing you in the divorce case you need to take a hard look to see if he/she committed malpractice. Where was the divorce case filed? In DC or in Maryland and if so, in what County. If you want me to review the correspondence you received from the DC Retirement Board I will be happy to do so. My email is marylandmediator@gmail.com and my office number if 301-947-0500. David DC Police and Firefighters SPD 2023.pdf DC Spouse Equity Act Information Statement-POLFF.pdf

Depends on the size of the client of course. We usually would only do SDBAs for everyone if the client was smaller than 10 participants. Pooled plans can be much larger.

Gadget we're likely taking this plan to a recordkeeper for this reason. The investment management subsides our administration. We've eliminated the option for hardship distributions, loans, and in-service distributions . The plan document makes terminated employees wait until after year end and after all contributions go into the account. It makes calculating their money types easier. Not really.

I don’t agree with this. We have lots of clients using a single brokerage account per person with multiple sources. We track all of them in our system despite different vesting schedules and distribution timing. It’s not really different than having a single pooled investment with the same things. These kinds of plans have existed for a lot of years before daily valuation services were created. ETA: "not" above

I’m not a fan of different accounts for each source. The only exception I would concede is maybe Roth money.

If the transaction happened in 2023, your 410b6c transition period ended last December. Will each plan pass coverage, etc in 2025 on their own?

I didn't see one single CORRECT answer. A retirement plan uses a trust to hold the assets. The trust is required to have it's own tax ID. PERIOD. Yes, of course you can ignore it and continue to hope that the IRS will never match income to tax IDs, but that doesn't change the answer. Ray, continue to do it the right way, regardless of what others have said.