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Regarding fees from the final QDIA regs:

Section ©(5)(ii)(A) shall not apply to fees and expenses that are charged on an ongoing basis for the operation of the investment itself such as investment management fees, distribution and/or service fees, ‘‘12b–1’’ fees, or legal, accounting, transfer agent and similar administrative expenses), and are not imposed, or do not vary, based on a participant’s or beneficiary’s decision to withdraw, sell or transfer assets out of the qualified default investment alternative;

Does this mean if the plan charges a $50 processing fee against a participant's account for the distribution of the QDIA within the first 90 days after the initial investment that is okay even if it wipes out the entire account value?

If the answer seems obvious, I apolgize.

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