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Participant-directed plan didn't happen--correction


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Plan as-written was participant directed but everything was invested in a pooled account.  For a bunch of years.

Currently, they are with a record-keeper and everyone is directing their stuff moving forward.

What's the fix for the prior years?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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I suppose the document might say if the participants fail to give the trustees their investment instructions, there could be a provision that it falls back to the trustees' prudent judgment.  And if a properly discloses SPD tells participant they can choose their own, and they then didn't go and choose anything.....

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