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Employer Reimbursement of Brokerage Account Expenses


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401k Plan Sponsor is depositing amounts to participant brokerage accounts to cover annual maintenance fees.  All participants have individual brokerage accounts.  Deposit per participant does not agree to exact Annual Account Maintenance Fee.  

I understand there is probably many potential problems with this scenario, but my question relates to whether it is "not allowed" for an employer to reimburse participant plan fees this way?  They are truly making individual deposits per person for a flat dollar amount.  

It has always been my understanding that if an Employer pays ANY money into a plan that it must be allocated as plan contributions based on the plan document.  Has anything surrounding this topic changed in the last few years?


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