Our office has been trying to make a determination on the new feature code 2T. Is this new code referring to a "general" default investment option contained within an investment contract or is it specifically referring to the QDIA rules? If other than a QDIA, what if a default investment option is available in the contract but isn?t being utilized because affirmative investment elections have been made by all participants? Should 2T still be used under these circumstances?

We have yet to see a participant directed contract that doesn't contain a default investment option and are not even sure under what circumstances that would ever occur. In which case, it would seem that if 2T isn?t for a QDIA, then every single filing we do with participant direction should have 2T listed. If so, what?s the point of having the code?

I think this was discussed recently and the conclusion was yes, use the code whenever a plan has provisions to default to an investment. It doesn't have to be a QDIA. I don't know that we've been consistent on that reply and am not too worried about whether it is right or wrong.



Be careful where you're going with that...at some point, you start to wonder what's the point of any of the crap we have to do...

I attended a webinar sponsored by a noted 5500 expert who stated it was the speaker's understanding that the code applies to any DIO not specifically to QDIO. This opinion is that of the speaker's interpretation, but thought this might be useful info for Board users.