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Posted

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.

Posted
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

Kurt Vonnegut: 'To be is to do'-Socrates 'To do is to be'-Jean-Paul Sartre 'Do be do be do'-Frank Sinatra

Posted

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.

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