Hi Karoline,
Did you ever receive an answer to this question? I am looking into a similar issue and based on what I have read it appears that the failure to timely provide a QDIA notice results in the loss of 404(c) fiduciary protection for the default investment. However, it is unclear whether the protection is lost for the entire Plan year if the QDIA notice is not sent at least 30 days prior to the first day of the Plan year or whether protection is provided beginning 30 days after the QDIA notices are sent.
If you additional information that is helpful and could provide that to me I would appreciate it.
Thanks!
