QDIA Notice Required in Spin-off

[Guest Lauren0507]

Company A maintans a plan subject to QDIA requirements. Company B is a subsidiary of Company A and participates in the Company A Plan. In 2014, a QSLOB election applies for Company B and there will be a spin-off from the Company A Plan to a new Company B Plan (to be effective March 1, 2014). Investments, including the default fund, will be identical in the Company A and Company B Plans. Company A distributed its annual QDIA notice in late 2013.

Of course a new notice for Company B must be prepared to distribute to new employees. Is Company B Plan required to distribute a new notice to partcipants who will be transferring to the Company B Plan as a result of the spin-off?

[BG5150]

I would say yes. Though related, it's still a separate plan.