When are "fees actually charged" to a participants account?

[Gudgergirl]

Regarding the quarterly fee disclosure for "fees actually charged (whether by liquidating shares or deducting dollars)...to the beneficiary's account..." DOL Reg 2550.404a-5©(2)(ii)

Plan pays quarterly fee for admin services. Participant accounts are valued annually and fee is charged to participants' accounts on a pro rata basis once annual val has been completed based on annual val account balances.

For quarterly fee disclosure purposes of "fees actually charged", do you think fees are charged when paid out of Plan assets (each quarter) or when allocated to the participant accounts (during last quarter or year)?

[BG5150]

Are these "individual accounts" participant directed? If so, they must get statements at least quarterly after PPA (I believe).

[Bird]

I'm not sure how you pay the fees quarterly and charge them to each account annually (balance forward?) but would show them when actually charged to the account.

(Good point about quarterly statements being required.)

[Gudgergirl]

The Plan has two components -

1. a self directed 401(k) part and

2. a Trustee directed Profit-Sharing part.

Quarterly statements include quarterly account info for the self-directed portion and show prior year end balances for the Trustee directed portion.