Pooled Investment Account Interest - no annual statement

[justanotheradmin]

TPA for a small PBGC covered plan, with various HCE and NHCE

A portion of the plan's money has been transferred to what appears to be a pooled off-shore account with a wealth management firm. No annual statements are produced, just a letter that says something like your starting interest as of 12/31/2024 is $X, P/L during the year was $Y, and end value of your interest in the pooled investment is $Z. 
The letter explains that statements are not available due to the pooled nature of the investment with lots of other investors. 

Off-hand I do not see anything prohibiting a pooled investment interest that would impact either an ERISA bond (non-qualified assets), or filing of a Form 5500-SF (must be eligible plan assets). Is there one? 
Other potential restrictions that should be asked about? There really isn't enough information to go on, so right now the goal is to make a list of questions for the sponsor and the wealth management company to address. 

So far: I intend to ask which is the categories of "qualifying plan assets" the investment is, in case the bond is not sufficient to avoid audit. 

What other questions /issues should be addressed? I feel like there are things we should ask about that I just don't even have an inkling about. 

Not a producing TPA, do not get involved in investment discussions, other than what is necessary for compliance, testing, reporting etc. 

Thank you all in advance for your insight. 

[Peter Gulia]

If there is a doubt about whether an asset is a qualifying or nonqualifying plan asset, here’s another opportunity:

A plan’s administrator might take protective steps as if the asset is nonqualifying. That includes paying for whatever extra fidelity-bond insurance would be needed.

Acting as if the asset is nonqualifying might be less expensive than getting a lawyer’s advice that the asset is a qualifying plan asset.

On a different point, a plan’s administrator, trustee, and every other fiduciary might take steps to satisfy all of them that “the indicia of ownership of [all] assets of [the] plan [are within] the jurisdiction of the district courts of the United States.” ERISA § 404(b), 29 U.S.C. § 1104(b).

Asking whether the plan’s trustee or § 3(38) investment manager sufficiently analyzed whether the asset is a prudent investment might be a point you prefer not to mention.

This is not advice to anyone.

[justanotheradmin]

Super helpful, thank you @Peter Gulia!