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Posted

Schedule I, Line 4(i) asks if the plan held 20% or more of its assets in a single security...In the instructions it specifically states that you do not check "Yes" for securities held as a result of participant directed transactions. Does this mean that if participant accounts are self directed we will not consider the value of such self directed accounts as being held in a single security? It seems that way to me, but this a pretty siginificant change from prior years so I am just looking for verification.

Posted

Remember that these questions are designed to determine if there may be issues with the fiduciaries. Are all of the plan assets in one investment?, for example. Participant directed investments are not the focus of the DOL, at least at this time. Also, most participants are investing into mutual funds either directly or under insurance contracts. These are monitored in other ways.

So, yes, you will exclude participant directed investments. In fact, if you have a characteristic code of 2G for item 8a on the 5500, 4i on the Sch I would be answered no.

Kristina

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