Fiduciary Sails Into “Safe Harbor” When Transferring Participant Investments To QDIA

In Bidwell v. University Medical Center, Inc., Case No. 11-5493, the Sixth Circuit found that plan fiduciaries are shielded from claims over investment losses where they transfer defined contribution accounts into a Qualified Default Investment Alternative (“QDIA”), after notice to the participant, even where the participant had previously made an affirmative investment election.

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