Gains applied to distribution from pooled acct in Dec.

[Richard Anderson]

We have a several clients with 401(k) plans that have pooled investments. We usually try to make distributions soon after an annual valuation. Our document provides for annual valuations and interim valuations if the plan administrator sees fit to do so.

Because of the new automatic rollover rules on mandatory distributions, we will be making quite a few distributions late this year. I would think that there may be a few others in the same situation.

If you are in the same situation; which of the following are you doing?:

1). Distribution based on 12/31/2004 valuation.

2). Distribution based on an interim valuation.

3). Something else (please specify)

Thanks

[WDIK]

Our document provides for annual valuations and interim valuations if the plan administrator sees fit to do so.

In my opinion there should already be in place a nondiscriminatory policy that indicates when the plan administrator would perform an interim valuation.

In this specific instance, I would look at how prior distributions have been handled and be consistent.