New Disclosure Requirements

[Dougsbpc]

The majority of the 401(k) plans we administer have all of their assets invested with one of the major platform providers. They will be able to provide the investment disclosure information.

What about small 401(k) plans that allow each participant a brokerage account? Identifying the investment alternatives and the investment performance of each investment alternative would be impossible as there may be thousands and thousands of investment alternatives. Does anyone know if this has been addressed in the new disclosure requirements?

[Bird]

Brokerage accounts get a free pass, sort of. They're not considered to be designated investment alternatives and you "just" have to provide a description of the brokerage window or account and you have to disclose the fees associated with the brokerage window or account.

What I'm concerned about are the plans that are using mutual fund accounts but are not on a platform, so the chart and other requirements won't be prepared by the custodian, and I don't think this qualifies as a "brokerage" account because it's a mutual fund account, effectively limiting the choices.