Participant 404a fee disclosures

[Belgarath]

I have a question on this. In a participant directed plan which has a brokerage window, assuming there is no specifically designated investment manager, who has the voting rights on stock purchased through that window? The Trustee because it is still a plan asset? Or the participant because the Trustee does not exercise "full management responsibilities?" I incline toward the former, particularly based upon DOL interpretive bulletin 08-02, but I'm not certain. A "standard" plan provision below:

To vote upon any stocks, bonds, or other securities; to give general or special proxies or powers of attorney with or without power of substitution; to exercise any conversion privileges, subscription rights or other options, and to make any payments incidental thereto; to oppose, or to consent to, or otherwise participate in, corporate reorganizations or other changes affecting corporate securities, and to delegate discretionary powers, and to pay any assessments or charges in connection therewith; and generally to exercise any of the powers of an owner with respect to stocks, bonds, securities, or other property. However, the Trustee shall not vote proxies relating to securities for which it has not been assigned full investment management responsibilities. In those cases where another party has such investment authority or discretion, the Trustee will deliver all proxies to said party who will then have full responsibility for voting those proxies

[SFSD]

We would send the proxy information to the directed account participant and request he provide instructions on how to vote. We'd then execute the proxies as plan trustee and submit them. Kind of doubt signatures are checked on proxies, but if they were, participant is not the owner of the securities, the trustee of the plan is.

[ESOP Guy]

I have a self directed brokerage account with an employer 401(k). I always get the proxy info. And anymore with electronic voting proxy I just go online and vote. As far as I can tell the trustee doesn't ever enter the picture.