With more firms gearing up to offer pooled employer plans (PEPs) and more employers considering whether to join a PEP, we have added a new resource page to NAPA Net.
At the start of 2021, the much-anticipated PEPs became official, allowing pooled plan providers (PPPs) to begin offering PEPs, letting unrelated employers participate in the same retirement plan without having to meet the any-common-nexus requirement that had been the standard for multiple employer plans (MEPs).
Before a PPP can start offering and operating PEPs, they must register with the Labor and Treasury departments to do so. The Department of Labor released a final rule in November 2020 on the registration requirements and many firms have already announced that they plan to offer PEPs, and have been registering with the DOL.
However, there still has been no final guidance issued by the DOL and IRS fleshing out the details on the employer and PPP responsibilities, including administrative duties, how to address noncompliant employers and the new reporting requirements. Moreover, many employers are still trying to decide whether they want to participate in the new offerings.
In the meantime, the final rule on the registration requirements advised that an employer or PPP will not be treated as failing to meet a requirement of guidance if the employer or PPP complies in good faith with a reasonable interpretation of the provisions before the issuance of such guidance.
To help navigate through these issues and serve as a one-stop resource for information about the new PEPs and PPPs, we have created a new resource page that includes links to the legislation, related regulatory guidance, ARA comment letters, and commentary and analysis by industry thought leaders.
The new MEPs, PEPs & PPPs resource page is here. In addition, you can browse our related news coverage here.
