If a plan selects Target date funds as their QDIA, do they have to base the target date on the plan's NRA, or can they base the target date on a uniform age for all participants, such as age 65?

For instance if a participant will reach the plan's NRA of 55 in 2030 and reach 65 in 2040, do you have to invest that participant in the 2030 fund or can it be the 2040 fund (assuming all proper notices indicate age 65 is the basis for the investment)?

Thank you for any assistance you can provide.

The exact words in the regs are "based on the participant’s age, target retirement date (such as normal retirement age under the plan) or life expectancy."

I'd see nothing wrong w/ using ages 65 or 67 as those are universal retirement ages (but would welcome dissenting opinions for anyone who's looked more closely at QDIA's than I have).

The regs can be found here: http://www.dol.gov/ebsa/regs/fedreg/final/07-5147.pdf