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TPApril

blackout period w/out moving recordkeepers?

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When changing advisors for a 401(k) plan, is it common to have a blackout period, even if the funds are staying at the same recordkeeper?

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Why do you ask?

A blackout period generally relates to some phenomenon that causes participants to be unable to give effective investment directions with respect to their accounts.  This presumes that participants have the right/power to direct investments.  Changing investment  providers or changing investment fund menus are probably the most common phenomena that cause blackouts.  While the change is occurring, there is enough going on so the service providers are unable to deal with the further distraction of accommodating investment instructions until after the changes are completed and the new arrangements are up and running.

Depending on what  you mean by "recordkeeper," a plan can have the same record keeper but still change investment providers or investment menus.  Your reference to "advisors" suggests that the investment arrangements are changing, such as the investment menu will be a different family of funds (e.g. changing from Vanguard to T. Rowe Price),  or the investment options are remaining within the same family or platform, but one or more designated investment funds is changing.

Also, "staying at the same recordkeeper" is not  adequately informative.  If the only change is that now adviser Joan will be paid a fee by the plan instead of adviser Jim, then a blackout is not implicated.

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If the new advisor is recommending changes to the fund lineup and the process of switching the funds takes greater than 3 days, it could trigger the need for a blackout because participants will not be able to complete certain transactions.

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Just throwing this out there, but it might be a case where someone saw the words "change" and "advisor" in the same neighborhood and knee-jerked to complete a checklist with "blackout" on it.

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In theory, if the person of the ER who is responsible for signing off on distribution is unavailable for more than three business days in a row there was a blackout, albeit, non-communicated.

Example:  HR director goes on vacation for a week and no one can make a distribution

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