plan takeover with pooled investments

We took over a profit sharing plan with 3 pooled accounts.  We have not dealt with pooled accounts in so many years, I do not recall how this had been handled.  In the past, participants had been given account balance statements combining the total of the three.

Like most plans, December lost money.  One participant is questioning her % of the loss and wants to know not only her breakdown of the three accounts (2 are CDs and one is invested with a broker), but her breakdown of the underlying investments in the brokerage account.

Furthermore, she says her attorney told her she has a right to see her portion of the breakdown of the underlying investments in her account balance statement.

3 minutes ago, thepensionmaven said:

We took over a profit sharing plan with 3 pooled accounts.  We have not dealt with pooled accounts in so many years, I do not recall how this had been handled.  In the past, participants had been given account balance statements combining the total of the three.

Like most plans, December lost money.  One participant is questioning her % of the loss and wants to know not only her breakdown of the three accounts (2 are CDs and one is invested with a broker), but her breakdown of the underlying investments in the brokerage account. 

Furthermore, she says her attorney told her she has a right to see her portion of the breakdown of the underlying investments in her account balance statement.

You should be able to show her how her earnings was allocated and what the basis for the allocation.   She doesn't get to pick and choose which assets she is invested in if this is a pooled account.  She is invested in the pool.

As for her portion of the underlying investments doesn't really make sense.  She is invested in the whole pool.  While it could be a pain I see no reason to not send her copies of the CDs and brokerage statements and say, "here is what the trust is invested in"   You account balance is x% of the total so in a sense you are invested in x% of all of these investments.  Since it is a pooled account you don't get to pick and choose which assets only apply to your account balance. 

But in the end I would stress the idea her account isn't invested in particular assets of the trust but all the assets in the trust.   And until the plan is changed to individual accounting that is how it is.  

PPA ('06) says* that participants have to get, essentially, a list of assets in those types of plans.  We prepare that for our clients, and it is fairly easy given the way we reconcile assets.  She doesn't have to have a breakdown per se (i.e. her share), but the list, which would show amounts for each investment, would tell her what she needs to know, or thinks she needs to know.   I guess you could just copy year-end statements and say "knock yourself out."  The provision is a (typical) well-meaning effort, probably introduced by some staffer, but really does nothing for anyone.  What is she going to do about/with the info?

*It also says that the DOL must provide regs on how to do this, within either 6 months or 1 year, I don't remember.  Still waiting.

1 hour ago, Bird said:

 

*It also says that the DOL must provide regs on how to do this, within either 6 months or 1 year, I don't remember.  Still waiting.

For years we joked about this provision in the law.  The joke got old before we got the regs.  

Isn't his what the SAR is for, and I would think this is the only thing she is entitled to see, besides an account balance statement showing her portion of the combined accounts?

17 hours ago, thepensionmaven said:

Isn't his what the SAR is for, and I would think this is the only thing she is entitled to see, besides an account balance statement showing her portion of the combined accounts?

They are entitled to much more, though not of any real value.  Go back and re-read Bird's response above.