5 Nuances to Managing Fiduciar y Liability with QDIA
fiduciary liability associated with the
new guidelines. While it is somewhat
easier to obtain 404(c) relief under
the QDIA umbrella, if you had those
404(c) practices already in place, you
can keep them intact by doing what you
were doing before the PPA regulations
were issued.
Third, while QDIAs offer plan sponsors
relief in some areas, they are still
responsible for prudent selection and
monitoring of appropriate QDIAs.
This includes documenting the due
diligence process that they followed
when choosing the QDIA. According
to the DOL regulations, consideration
of all costs and fees are important to
the selection process.
Fourth, communicate, communicate,
communicate. Don’t neglect the
requirement to notify any defaulting
workers that they are being defaulted,
and that they have a right to opt out—
both at enrollment and annually.
Finally, while it is true that QDIAeligible investments offer convenience
to both plan sponsors and participants,
they aren’t the only prudent choice for
a default option. A well-considered,
researched and carefully monitored
investment can still be a suitable choice
for many plans — even if it doesn’t
meet QDIA requirements.
objective guidance to help you sort
through how QDIA rules impact your
plan…and determine whether a current
default investment option complies
with current QDIA regulations. n
(1) The opinions voiced in this material are for
general information only and are not intended to
provide specific advice or recommendations for
any individual. (2) Securities and Advisory services
offered through LPL Financial, a Registered
Investment Advisor. Member FINRA/SIPC. (3)
The LPL Financial Registered Representatives
associated with this site may only discuss and/
or transact securities business with residents
of the following states: AZ, IN, IL, MI.
As an independent financial advisor
who primarily focuses on retirement
plans, I can provide the insight and
www.conferomag.com | 21