Directed Investment Policy Issues

[chris]

Main issue is how to deal with discrimination issue as to setting a $$$ threshhold as to when a participant can and cannot direct the investment of his/her account..... Is it a matter of picking a $$$ threshhold low enough that some NHCE's can elect to direct the investment of their accounts? For example, e/er doesn't want participant with $1200 in his account to elect to direct the investment b/c of add'l admin charges by plan bookkeeper/accountant. Really becomes an issue when 50 participants with small balances want to elect to direct the investment of their accounts. Looking for any guidance as to setting a $$$ threshhold, if applicable, or for alternative manner of delineating who can/cannot elect to direct the investment of their accounts..... Thanks in advance...

[mbozek]

Self direction of accounts is a benefits rights and features issue which must be applied on a non discriminatory basis. If the only persons who will not be able to self direct investments are nhces then I think the plan flunks the brf test regardless of the $ dollar amount

[chris]

To sum up your post...regardless of the dollar threshhold, if the only people that are prevented from self directing are NHCE's, then there's a clear discrimination issue...? I guess the difference b/t a dollar threshhold re self directing and a dollar minimum requirement for loans is that the reg's. allow for a minimum to be set on participant loans...? Wouldn't setting the threshhold at a point where some of the NHCE's can self-direct be an argument against discrimination in favor of HCE's? There may have been prior posts on this next issue, but what about the effect of the TPA charging each self-directed account $x per $1000 of acct. balance for admin. costs (bookkeeping, balancing, etc...) or some similar type of arrangement?