QDIA Requirements for EACA and QACA under SECURE 2.0

It is my understanding that the QDIA is required for affected plans (that employ more than 10 employees) that use the required EACA feature under the SECURE 2.0.

Is there a QDIA requirement for QACA plans also (assuming the plan employs more than 10 employees and must have an Automatic Contribution feature)?

Thanks!

I would think "yes" since the QACA is also an EACA.

All automatic contribution arrangements - ACAs, EACAs and QACAs - must have QDIAs as a default investment election.  This covers the situation when an employee is automatically enrolled and deferrals are taken from the employee's pay by default.

• A plan can be an ACA without being an EACA or a QACA.
• A plan can be an EACE without being a QACA.
• A plan can be a QACA without being an EACA.
• A plan can be both a QACA and an EACA.

Asking a plan sponsor what they would like to have in the plan for employer contributions, vesting, testing extension, ... is like asking your kids what flavor or flavors of ice cream they would like to have on their ice cream cones.

Thanks Paul.  What makes a QACA not an EACA?