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ARTICLE · 26 NOVEMBER 2020

Diving Into The Pooled Plan Provider Deep End? It's Time To Register!

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Pooled plan providers hoping to start operating pooled employer plans in 2021 will finally have the ability to register to do so...

United StatesEmployment and HR
Stephanie B. Vasconcellos
Stephanie B. Vasconcellos
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Pooled plan providers hoping to start operating pooled employer plans in 2021 will finally have the ability to register to do so, under regulations finalized by the Department of Labor ("DOL") on November 16, 2020.

As described in detail in our prior alert, the SECURE Act created a new type of retirement vehicle called a “Pooled Employer Plan,” or PEP, in which multiple unrelated employers may participate and which may be sponsored by entities including financial services companies, such as banks, insurance companies and third-party administrators. The sponsors, referred to as “Pooled Plan Providers” or PPPs, are responsible for most fiduciary and administrative duties related to the PEPs they sponsor. The SECURE Act permits a PPP to begin sponsoring PEPs as soon as January 1, 2021, provided the PPP meets the SECURE Act's requirements, including registration with the DOL and IRS before commencing operations. The DOL issued proposed regulations on August 20, and in

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