Non-participant directed disclosure

[Guest Melissa5374]

The employer restricts the ER contributions to an Interest Accumulation Account which is classified by the custodian as a cash & cash equivalents account per the statement issued by the Custodian below:

However, when we conducted an evaluation of the characteristics of the General Account, we concluded that the General Account was comparable to a cash equivalent and therefore exempt from classification as a Level 1, 2 or 3 asset under ASU 820-10 for the following reasons:

• There are no front- or back-end charges, so investments in the General Account are completely liquid;

• The interest rate credited to investments in the General Account is a current rate, and is not dependent upon the length of time the assets are invested with Mutual of America;

• Requests for withdrawal can be made at any time and are processed on the day that they are received; they are not dependent on the Company having to liquidate securities in order to generate a payment; and

• The value shown on the pension fund report is the redeemable value of the fund; there are no deferred sales charges, load assessments or interest rate adjustments that would affect the value as a result of a withdrawal request.

So, my question is since the account is not considered an investment, do I have to break it out as nonparticipant directed in the footnotes and disclose the cost on the Schedule of Assets Held?