Feature code 2R in the Department of Labor's Form 5500 instructions denotes a plan that offers participants a self-directed brokerage account, commonly called a brokerage window. In practice it means a participant can hold investments outside the plan's preset fund menu, inside the same tax-sheltered account.
It is not a product, a share class, or a fee arrangement. It is a design decision the plan sponsor made, or never made, when the plan was set up, and it is reported once a year in a single field.
If 2R is present, a participant—or a professional acting for one—may manage that account in real time. If 2R is absent, the money is managed only through the preset fund menu. Everything else about the plan sits downstream of that one distinction.
A plan with no brokerage window confines every dollar to the fund lineup the provider selected. An owner usually discovers the cost only in a bad quarter.
Nobody, not you and not an adviser, can adjust a participant account intraday. Orders queue and execute at the closing net asset value, so a decision made at ten in the morning is filled at a price nobody knew when it was made.
If the lineup omits an asset class, that asset class simply does not exist for your employees. Diversification stops at the edge of a list you did not write.
Preset menus are frequently populated with funds that pay revenue sharing back to the recordkeeper. Without a brokerage window, participants have no way to leave that lineup, so the arrangement keeps collecting fees.
Search your company or plan name in the Department of Labor's EFAST2 filing search, open the most recent filing, and read line 8a on a Form 5500 or line 9a on a Form 5500-SF. The codes are printed in a row. You are looking for the characters 2R.
Most small plans file the short form, Form 5500-SF, which still reports plan characteristics codes, on line 9a of that short form. So 2R remains checkable even when almost nothing else in the filing is. Fees and fiduciary terms, by contrast, live in plan documents and 408(b)(2) disclosures that are never filed publicly.
If you find 2R, the next question is whether anyone is actually using it. If you do not find it, the next question is why the plan was built that way, and who benefits from it staying that way.
A brokerage window widens what is possible, which cuts both ways. It permits professional discretionary management inside the plan, and it also permits an untrained participant to concentrate a balance badly. The ERISA answer is not to withhold the window but to supervise how it is used.
Adding a self-directed brokerage option is usually an administrative amendment rather than a new expense line for the company. What changes, and what providers rarely volunteer, is that assets can then leave the preset menu, which can reduce the revenue sharing the incumbent collects.
It means the structural constraint is not present. It says nothing about what the plan costs, who is paid out of plan assets, or whether the named fiduciary has been monitoring either. Those are the other two things we look at.
One finding and two questions, from your own Form 5500, within two business days. No call required, no cost, and nothing to sign. Companies of ten to fifty employees with roughly $1 to $5 million in plan assets are the ones we can help most.
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GlacierWealth, Inc. is a fee-only Registered Investment Adviser, independent since 2001. This guide is informational and educational only: not investment, legal, tax, or accounting advice, and not personalized to any reader's circumstances. Form 5500 filings are public but may be incomplete or outdated, and any observation drawn from one is confirmed against plan documents before it is relied on. Descriptions of ERISA obligations are general; consult your own counsel about your plan.