6th Circuit Rules on QDIA: Detailed Analysis
An in-depth analysis of the 6th Circuit's ruling on Qualified Default Investment Alternatives and its implications for plan fiduciaries and 3(38) investment managers.
David Witz1 min read81 wordsOne of the many responsibilities of an ERISA § 3(38) Investment Manager (“IM”) is the selection, monitoring and replacement of investment alternatives including a Qualified Default Investment Alternative (“QDIA”).
The 3(38) Investment Manager’s QDIA Responsibilities
Adopting a QDIA is a fiduciary decision that is best determined in collaboration with the 3(38). If a 3(38) is appointed to select or replace the QDIA, the Plan Administrator is ultimately responsible for ensuring all disclosure obligations are provided.
Conclusion
A safe harbor is only a benefit if you follow the requirements explicitly.
