404(c) compliance

[Guest le190]

A self-directed 401(k) plan limits fund transfers between funds to up to 25% of the participant's account balance. Only once during your time in the plan can you transfer an unlimited amount between funds.

The reason is the fund liquidity issue with the investment manager. Does this restriction comply with section 404©?

[Guest Paul McDonald]

I would say you only have possible 404© protection for 25% of the money and possibly not even that. Assuming you have at least three diverse "Core Funds" available to choose from, the regulations call for unlimited fund transfers among the "Core Funds" allowed at least quarterly and possibly more often depending upon the risk characteristics of the core investments. The restrictions you mention make it such that a participant does not have the opportunity to exercise control over their account balance.