PCRA accounts and pay to play rules

Is anybody familiar with Schwab PCRA accounts (Personal Choice Retirement Accounts - http://www.schwab.com/public/schwab/investing/accounts_products/accounts/pcra) and how they fit into pay-to-play rules if the underlying plan is a a "government entity"? It's essentially a self directed brokerage account of the participant, so the client is the participant and not the plan. Curious to know if the same pay-to-play recordkeeping rules and contribution limits are triggered as with a more traditional "government entity" plan client.

Thank you for any insight.
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