The QDIA You Pick Today Might Be Wrong Tomorrow

Ary Rosenbaum - The Rosenbaum Law Firm P.C.
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Ary Rosenbaum - The Rosenbaum Law Firm P.C.

If there’s one consistent truth in the retirement plan world, it’s that nothing stays consistent—especially the Qualified Default Investment Alternative (QDIA). Yet for some reason, many plan sponsors treat picking a QDIA like picking a couch: choose it once, stick it in the corner, and hope it still looks good a decade later. The problem is, unlike a couch, a QDIA actually requires maintenance. It’s not supposed to collect dust; it’s supposed to collect returns.

Target-date funds (TDFs) are the most common QDIA, and rightfully so. They’re diversified, easy to explain, and—best of all—participants don’t have to do anything. Unfortunately, that same “set it and forget it” attitude has infected plan sponsors. A TDF lineup is not a Ronco rotisserie oven. You don’t pick it, walk away, and shout “Set it and forget it!” as if fiduciary responsibility begins and ends at the 404(c) safe harbor.

The truth is simple: markets change, fees change, glide paths shift, investment teams turn over, and participant demographics never stay still. A QDIA that made perfect sense in 2017 might be completely inappropriate in 2025. And if the Department of Labor ever comes knocking, “But our advisor picked it eight years ago” is not going to be the winning defense you think it is.

Reviewing your QDIA annually isn’t just good governance—it’s survival. Did the fund underperform? Did the glide path become too aggressive or too conservative? Are the fees still competitive? Did the investment manager leave for a competitor? Did your workforce suddenly skew younger or older? If the answer to any of these is “I don’t know,” congratulations: you’ve wandered into fiduciary danger territory.

A QDIA is one of the most significant decisions a plan sponsor makes, because it affects the people least likely to make their own investment decisions. That’s a lot of responsibility. And like any responsibility, it requires ongoing attention.

So don’t treat the QDIA like the treadmill in your basement—used enthusiastically once and then ignored. Check it. Review it. Document it. Your participants, your fiduciary file, and your future self will thank you.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© Ary Rosenbaum - The Rosenbaum Law Firm P.C.

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Ary Rosenbaum - The Rosenbaum Law Firm P.C.
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