QDIA's

[austin3515]

Just to be clear, do we all agree that the QDIA rules are impossible to comply with in the real world, particularly the small employer world? (and I know they're just safe harbors).

-For example, 30 days before the contribution is funded, you may very well not even know if there is going to be a contribution.

-OR let's say you play it safe and tell clients to distribute the notice in January, and then they don't fund until September 15th. An 8 month delay seems like a bit of a stretch for a notice.

-And how many people are really sending out additional annual notices to plan participants who never changed the default?

Real world answers only please

As a follow-up, I had heard from someone who had heard that the money market might return as an acceptable default investment. Anyone else hear that?