one time election to investment in property

[SheilaD]

My client says they did this with a prior administration firm in the past. (of course)

This is a totally participant directed plan and the trustees are going to make a "special" investment of Trust assets in a piece of foreign property. A notice is to go to all active participants stating that they have a one time option to invest in this property with lots of notes about how highly speculative, aggressive etc this investment is. Any participant may elect to direct some of their account into this investment. (Assumption being that they have enough owners who want to be in this investment that they can cover the purchase price). Once in the investment it will be treated like a pooled fund - with annual valuations. Participants with a share of this investment can only get out of it in the month following the annual appraisal. Once in a participant can only get out of it entirely (i.e. if their share is 10,000 they can transfer out the total but not 50% of it). I've not seen this before and would welcome any thoughts.

My initial concerns regard the fact that it is a directed and yet pooled investment. How does this effect fee disclosure, quarterly valuations, etc.. Would this be similar to allowing participants to keep some of their assets in a trustee directed fund?

Thank you in advance.

(edited to add more information).

I am now informed that one participant wants to borrow money from the plan to invest as an individual as well.