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This is my first time posting in here so I really appreciate any feedback. The client has a pooled account that contains the account balances of all participants however the client allows participants to pick investments within the pooled account. The account is valued annually. Historically when a participant is paid out they are given their distribution based upon the last valuation done and do not share in gain/loss that occurs between valuation date and date of distribution. The gain/loss is divided up among the remaining participants within those specific funds. The basic plan document states that gains/losses in a pooled account with participant investment discretion should be applied reasonably. The plan recently had a participant who took a distribution based on the last valuation date. In the following valuation period, it was discovered that the participant paid was the last participant who was invested in a couple of the funds therefore there we no longer had any remaining participants in the fund to be given the investment gain. How should that gain be applied? Should the gain go to that specific participant and he would be given a trailing distribution on those funds or should the gain go to the rest of the plan participants since historically no other participant ever received a gain after they took their distribution? My concern is that if I give him the gain when one has never been applied in the past to other participants, that this would be discriminatory. I also have a hard time in giving him a gain in only some of the funds he was invested in. If I think he is entitled to the gains to the 4 funds that he was the last person invested in, shouldn't i need to give him gains on all the funds that he was invested in? I try to think about what I would have done if the plan had experienced a loss and there was not enough funds to pay him out. I probably would have told the client that I needed to do an interim amendment and in that case he would have received the gain/loss through the interim date but again that would have been based up a new valuation being done.