Please settle and argument for us. The QDIA Notice is required anytime there is a QDIA in the plan. It applies to plans "with" and "without" ACAs, EACAs, or QACAs.
Thanks.
Full Version: QDIA Notices
QUOTE (DTH @ Jan 29 2008, 06:14 PM) 
The QDIA Notice is required anytime there is a QDIA in the plan. It applies to plans "with" and "without" ACAs, EACAs, or QACAs.
I would agree; an ACA/EACA/QACA is not specified by the regs as a condition to either having a QDIA or providing the QDIA notice. A possible point of confusion is that the ACA notice and the QDIA notice can be combined. http://www.dol.gov/ebsa/regs/fedreg/final/07-5147.pdf
If a participant makes a deferral election and has the right to direct the investment but does not choose an investment, then the trustee/fiduciary has the money placed into a default fund. In order for that trustee/fiduciary to have 404©(5) protection regarding that default fund, the fund must be a QDIA and the QDIA notice is required.
This is a "lo-fi" version of our main content. To view the full version with more information, formatting and images, please click here.