The new diversification requirements under the Pension Protection Act generally apply only to DC plans holding publicly traded employer stock. However, the rules generally provide that where the plan holds employer stock that is not publicly traded, it will be treated as publicly traded if the employer (or any member of the employer's controlled group of corporations) has issued a publicly traded security. I have a client which holds employer stock in their plan that some 5 or 6 years ago was publicly traded but is no longer (having gone private). Does anyone have any insight on how this new rule will apply? How far back will we have to look? Has there been any discussion on this?