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Posted

I'm reading an SPD that says the plan intends qualify under 404©. The paragraph is very brief. It simply says that participants are responsible to make their own investment choices and that the plan fiduciaries are not responsible for any losses that might occur.

Most of the SPDs I read go into much more detail about what 404© means.

Is there any specific language that is required to be provided relating to 404©?

Posted

There is an extensive list of information that must be provided to participants if a plan wishes to be 404© compliant. That list can be found in 29 CFR 2550.404c-1, here.

The SPD is a logical and convenient place to disclose part of this information. If the plan in question is providing what is necessary separately, I think it is fine.

...but then again, What Do I Know?

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