SECURE Act Update: DOL Publishes Proposed Rule On Registration Requirements For Pooled Plan Providers

For plan years beginning after December 31, 2020, the SECURE Act (Setting Every Community Up for Retirement Enhancement Act) removes possible barriers to the broader use of multiple employer plans (MEPs). Under rules enacted by the SECURE Act, unrelated employers will be able to more easily band together and provide retirement benefits under a pooled employer plan or PEP, which is a type of MEP. PEPs are individual account plans that will offer small employers, without the need for any commonality among the participating employers or other organizational relationship, access to qualified retirement plan benefits while potentially achieving cost and administrative efficiencies that are more easily realized by larger plans with larger participant pools and larger quantities of investible assets. A PEP is maintained and administered by a pooled plan provider (PPP) who is designated to act as the plan's named fiduciary, and is responsible for performing all administrative