Valuation Date for 401(k) Plan

This is a plan document question and also relates to 404(c).  The plan allows participants to self-direct investments in individual brokerage accounts.  This is NOT an investment platform, but the total asset balance in each participant's account can be obtained each day online or with a phone call as the funds are publicly traded.  I believe this makes it a daily valued plan (must be indicated in plan doc) and it can be 404(c) compliant if meeting other requirements.  A plan that is not daily valued cannot be 404(c) compliant.  Question - The money type balances are only determined on annual basis by yours truly (TPA).  Does this change it from being a daily val plan to an annual valuation plan that cannot be 404(c) compliant?  I see nothing about source/money type balances in the regs, but want to be sure we are drafted documents to reflect a correct valuation date (daily vs. annual).

Thank you in advance for your feedback!

Can they change their investments in the money market funds at least once per quarter?

I guess another question I would have is how about the vesting?  If you are only doing money type balances annually, even if the participant can get values daiily how do they know their vested portion?  Then again I can't remember if 404c states that vesting only need be provided once annually?  Perhaps there isn't any money in this plan subject to vesting?  just food for thought...

404(c) is investment related.  I don't see where vesting comes into play.

And, I don't think daily valuation is a requirement either, just that the participant must have control over the investments.

Nothing in there says that an investment be immediately under the control of the participant.  The plan can impose restrictions on the frequency of changes.  I believe the participants must be able to give instructions at least once every quarter.

I think is was the "final" 401(k) regs that added the vesting requirements to the statements?  Or, at least, something after EGTRRA.

Here's the 404(c) reg:

https://www.law.cornell.edu/cfr/text/29/2550.404c-1

6 minutes ago, BG5150 said:

The plan can impose restrictions on the frequency of changes.  I believe the participants must be able to give instructions at least once every quarter.

Which is why I asked. If the answer is yes, then no reason why this cannot be 404(c) compliant.

Yes this scenario is daily valued and can be 404(c) compliant.  

Thanks, all!

What BG5150 said.