Pooled and Individual Account Mix - PPA Requirement

[Pixie]

My client funds employer benefits in a pooled account. 401(k) contributions are deposited to individually directed accounts with quarterly statements. I have been providing an Annual Statement with vesting, and a quarterly notice of multiple statements and PPA quarterly notice.

My question is, under PPA, how often am I required to value the pooled account? Currently, I have been valuing it annually.

[J Simmons]

My client funds employer benefits in a pooled account. 401(k) contributions are deposited to individually directed accounts with quarterly statements. I have been providing an Annual Statement with vesting, and a quarterly notice of multiple statements and PPA quarterly notice.

My question is, under PPA, how often am I required to value the pooled account? Currently, I have been valuing it annually.

Quarterly. You have a plan that has individual accounts that allow participant direction of investment. That means the benefit statements--of all benefits in the plan--are due quarterly.

[Bird]

I don't think the pooled piece has to be valued annually, although I think PPA does say that quarterly statements are required (i.e. you can just spit out the same 12/31 values each quarter). I also think there was some kind of guidance relaxing that useless reporting requirement but would have to look it up and am not in the mood today. Unless someone backs me up, I'll follow up later (maybe).