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We are converting a plan that will map all participants to Target Retirement Funds (QDIA). We are providing a 30 day window to allow participants to choose a different allocation if they would like to. This "window" will close 2 weeks prior to the date assets are received and invested.

The plan also has automatic enrollment.

I have two questions:

1. Will closing the "window" two weeks prior to assets being mapped to the Target Retirement Fund still qualify the plan for 404 © protection.

2. If someone is automatically enrolled in the plan at the prior recordkeeper during the 30 day window (meaning this person will not be on our companies systems). How does the 404 © protection apply since these individuals may not have a full 30 days depending on when they are automatically enrolled at the prior recordkeeper I'd like to know what the options are for this scenario? Will a communication to all individuals who are to become eligible during this time outlining the process suffice or are there special issues that may need to be considered around this?

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