Designated Roth Deferral - Separate Account

[MarZDoates]

According to IRC 402(A)(b)(1), a roth deferral must be maintained in a separate account. Does this literally mean a separate investment account earmarked for Roth deferrals? Can you not have a pooled investment account and just separately account for the roth deferrals, earnings, etc.?

Thanks for any and all input.

[chc93]

We have a small plan with pooled trust assets and a ROTH deferral "money source" in addition to other money sources (employer PS, regular 401k deferrals, rollovers, etc). As you say, I thought the "separate account" only meant to keep the ROTH account separately accounted for its own share of gains, contributions, etc.

[Belgarath]

Agree. It is separate accounting - I see no theoretical problem with a pooled account that has separate accounting for the Roth piece. Also see 1.401(k)-1(f)(2).

[MarZDoates]

Thank you!