QDIA notice - who is responsible ?

I’ve been out of the business for a few years, in that time QDIAs came into being. My employer (a TPA) is telling me the QDIA notice requirements fall on the fund companies we work with (examples: Transamerica, Nationwide, Voya, Hancock) and the Plan’s financial advisor. We as TPA do nothing with the QDIA notice. This doesn’t seem right to me. I had a financial advisor tell me he expects the TPA to take care of it. How do other TPA firms handle the QDIA notice requirements? 

We provide the notice to the sponsor along with instructions/deadline info. The recordkeeper's annual fee disclosure may or may not include the appropriate language, but it's a minor thing to take care of... especially for safe harbor plans where you're already providing the annual SH notice anyway.

Ultimately the responsibility falls on the plan administrator, and as somebody who's expected to help the plan administrator meet the requirements and responsibilities of the plan, I wouldn't be at all comfortable saying "I just assumed John Hancock was doing it" if it ever became an issue.

(edited: plan administrator, not sponsor!) 

The QDIA notice is the responsibility of the Plan Administrator.  And the sponsor.  it is a fiduciary responsibility.

Often, the record-keeper or platform provider (or whatever term you prefer) such as Voya or John Hancock, etc., can and will provide the notice to the PA.  Sometimes they will distribute it, too, but it is still the PA's responsibility to make sure its done.  

Sometimes the plan document software can provide a template, and whomever usually prepares the documents can fill in the appropriate values and generate the QDIA. Again, it is the PA's responsibility that it's done.  (Some plans contract with a 3(16) Plan Administrator to get it done.)

In absence of the document provider or the investment provider, the financial advisor's office can (and should) help develop the notice.

But in the end, it is still the Plan Administrator's responsibility.  If the PAS cannot produce a compliant notice, they he or she should (must) contract with someone who can.

As always, go back to your administrative service agreement with the clients.  If you as the TPA did not agree to provide the service, then the reponsbility falls on the Plan Administrator.