404(c) Protection

[Nassau]

ABC Company has a 401a and a 403b. They would like to map participants who have previously been defaulted into a money market fund into the age appropriate Target fund.

Plan has 3 providers. Would they need to do this for all employees?

The plan has not chosen the TRFs as the QDIA. They only have it set up as the default. Would they be required to have all 3 provider lifecycle funds as QDIAs in order to get ther 404c protection when mapping the assets?

[J Simmons]

For the QDIA protection, they would need to select only one managed fund, balanced fund or life-cycle fund that meets the QDIA requirements and then 'map' as you say all the benefits of all the employees who've not given an investment directive (i.e., in the money market fund) into the selected QDIA. You would not need to select more than one QDIA. You do not need to select a QDIA from each of the 3 providers.