Participant directed vs non-particpant directed

[Guest todd]

If an employer match is required to be invested in a money market account rather than allocated according to the participants selected investments, is this considered non-participant directed? Participants may move the match money after fully vested. Also once employees are fully vested the match mirrors the participant's selected investments. Is the match considered participant directed or non-participant directed??? If non-particpant directed additional footnote disclosures will be required.

[MR]

Todd, I may be missing something here, but the match that is required to be invested in the money market fund because the participant is not fully vested is considered trustee-directed, not participant directed. Once the participant becomes fully vested and the match mirrors the 401(k) investments, it becomes participant-directed. I'm not sure what the purpose of your question is, but with this plan, it sounds like you have some match accounts that would be considered participant-directed and some that would not.