Guest Tom: Posted April 4, 2011 Posted April 4, 2011 We are changing our investment fund line-up and to preserve 404© fiduciarly protection we are unsure whether to rely on the "qualified change in investment option" (QCIO) mapping rule under 404©(4) or the "qualified default investment alternative" (QDIA) rule under 404©(5). It seems safer to default everyone who fails to provide new investment instructions with respect to investment options that are being eliminated into our QDIA so that we don't have to worry about any amounts previously defaulted into the eliminated funds. This is besause 404©(4)©(iii) requires amounts invested prior to the change to be invested as "the product of the exercise" of the participant. In fact, becasue the QCIO rules are more complicated (and due to the lack of QCIO guidance from the IRS), it seems like it would always be a poor choice to rely on the QCIO mapping rules. Does anyone have other thoughts?
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