408(b)2 and 404(a) for Trusteed Pooled Plans

[rfahey]

Does anyone know if the new cost disclosure rules that apply to 401K plans also apply to profit sharing only plans whose assets are invested by the plan trustee and are pooled together. These plans only get valued once a year. Partyicipants have no control over the investments.

THank you

[Jim Chad]

FWIW I believe that 404a does not apply because there is no Participant direction of investments. But 408(b)(2) does apply.