We have a client that is the Administrator of a 80-100 Group Trust and our organization is the directed trustee. They want to retain the funds of those participants who are requesting direct rollovers to IRAs from the 401k plan. It is our understanding that legislation now allows for these types of IRAs under the Group Trust as long as the plan is amended to include the language. We have Operational and Compliance questions regarding this type of arrangement and would like to know if anyone has any experience with such an arrangement.