QDIA Notice Issues

[EPCRSGuru]

I am a new HR employee for a plan sponsor whose retirement plans are in a "multi-vendor environment." There are three investment companies whose funds are available; one of them is designated as the master record-keeper but there are various logistical problems with that arrangement so there is no central source for the employer to obtain information. Vendor X's lifecycle fund family is designated as our QDIA--the actual default fund depends upon the participant's DOB.

Participants who make no election are placed in the Vendor X lifecycle fund, which is fine. However, I have discovered that some participants designate Vendor Y or Vendor Z as their investment provider of choice, but then do not proceed to name a fund. If the vendor receives a contribution from us with no investment instructions, it defaults into its own lifecycle funds, not the Vendor X fund that is designated as our official QDIA.

Does anyone besides me think that is a problem? It seems to me that we need to a) retrieve the money from Vendor Y or Z if there are no instructions and invest it with Vendor X, b) track down the participant to get a Vendor Y or Z fund designation, or c) add the Vendor Y and Z lifecycle funds as "official" QDIAs.

The answer to this question affects the content of our QDIA notice as well as who provides it. There has been some discussion of having the vendors provide the Notice, but is it fair to Vendors Y and Z to ask them to send out notices describing the Vendor X funds?

Any thoughts are welcome. Thanks!

[PensionPro]

You should have a QDIA notice that specifies the default fund for each vendor. Also if no vendor is chosen then the default vendor. Here is one example: http://benefits.jhu.edu/documents/QDIANotice.pdf

[EPCRSGuru]

You should have a QDIA notice that specifies the default fund for each vendor. Also if no vendor is chosen then the default vendor. Here is one example: http://benefits.jhu.edu/documents/QDIANotice.pdf

Thank you. That is what I thought but I felt like I needed some reinforcement before I raise the issue. Appreciate the help!