Self-Directed Brokerage Accounts in Multiple Employer Plan

[kevind2010]

Does anyone know if it's ok to have a Multiple Employer Plan where one non-related participating employer allows participants the option of Self-Directed Brokerage accounts while the other participating employers do not give this option to employees? If I understand, an MEP is treated as a single employer for eligibility, exclusive benefit rule, vesting, and Section 415 limits. To my knowledge, allowing SDBA's for only employees of certain employers wouldn't violate any of these. Am I correct or perhaps overlooking something? Any input is appreciated!

[ETA Consulting LLC]

I think you're reading too much into it. The SDBA is still an asset of the plan. If anything, it would be a Benefits, Rights, & Features issue; since this is tested to the single employer, there shouldn't be an issue.

Good Luck!

[kevind2010]

I think you're reading too much into it. The SDBA is still an asset of the plan. If anything, it would be a Benefits, Rights, & Features issue; since this is tested to the single employer, there shouldn't be an issue.

Good Luck!

I figured I may have been reading too much into it. Thanks!

[Guest Jim K]

Unrelated employers may have different investment menus within a multiple employer plan although it may not be pragmatic to do do from a fiduciary's perspective. Benefits, Rights and Features testing would not apply. If an adopting employer is a member of a controlled group within the MEP, then the same investment menu should apply for all CG members. Hope that helps. Happy holidays.