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Is the unitization of a target-date fund in a 403(b) permissible?


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Guest BenefitsGal5
Posted

Custodial accounts that are investe solely in mutual funds are one of the permisisble funding arrangements in a 403(b) plan. If a target date fund in the 403(b) plan is unitized may it still be considered a mutual fund?

Posted
Custodial accounts that are investe solely in mutual funds are one of the permisisble funding arrangements in a 403(b) plan. If a target date fund in the 403(b) plan is unitized may it still be considered a mutual fund?

The custodial account content requirement is that the investment be in a regulated investment company. That is, registered with the SEC as such.

If the plan has a retirement income account, it can invest in a wider variety of vehicles. However, a hard answer would require looking at the detailed facts.

Tom Geer

Thomas L. Geer, J.D., LL.M.

Benefit Plan Solutions

Blog: http://401k-403b-457-plansblog.blogspot.com/

Email: geertom@gmail.com

Phone & Fax: (888) 315-6720

Guest BenefitsGal5
Posted

The custodial account content requirement is that the investment be in a regulated investment company. That is, registered with the SEC as such.

If the plan has a retirement income account, it can invest in a wider variety of vehicles. However, a hard answer would require looking at the detailed facts.

Tom Geer

Are you suggesting that if the plan has a retirement income account (RIA), and if the target date fund is moved to the RIA, then the target-date fund can be unitized? Are you also suggesting that if the target date fund remains in the custodial accounts that it cannot be unitized?

Posted

The custodial account content requirement is that the investment be in a regulated investment company. That is, registered with the SEC as such.

If the plan has a retirement income account, it can invest in a wider variety of vehicles. However, a hard answer would require looking at the detailed facts.

Tom Geer

Are you suggesting that if the plan has a retirement income account (RIA), and if the target date fund is moved to the RIA, then the target-date fund can be unitized? Are you also suggesting that if the target date fund remains in the custodial accounts that it cannot be unitized?

Actually, I was trying hard not to say anything definitive. Is the target date fund a regulated investment company, registered as such with the SEC? In the alternative, is it a bank collective investment fund or a managed pool of assets with a target date management style? It could, in theory, be a pooled separate account of an insurance company held under a life insurance policy or some variation of a master trust. Is it? The term "fund" has too many meanings to be the basis for real-world advice.

Tom

Thomas L. Geer, J.D., LL.M.

Benefit Plan Solutions

Blog: http://401k-403b-457-plansblog.blogspot.com/

Email: geertom@gmail.com

Phone & Fax: (888) 315-6720

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