Plain Language on MEPs, PEPs and 'Groups of Plans'

To understand a new law, it’s often helpful to read the actual law – especially since, in the case of the SECURE Act, we may well be waiting on IRS and DOL regulations for much of 2020. But what if you want to know what that legislative language actually means?

Either way, Pentgra Senior Vice President Pete Swisher has crafted a “summary and plain language version of SECURE’s multiple employer provisions.” For those who want to peruse the actual text, that is available in Swisher's white paper, as it relates to multiple employer plans (MEPs), pooled employer plans (PEPs) and “groups of plans.” Preceding the full text is a summary that includes notes on what the bill actually means for the retirement plan community.

Of course, a PEP is a MEP sponsored and governed by a pooled plan provider (PPP), who is a named fiduciary of the plan and its 3(16) plan administrator, and can be a service provider (e.g., recordkeeper, TPA, bank, broker-dealer, RIA). Not all MEPs will be PEPs – there are still Association Retirement Plans and other pooled plans that qualify as single plans. “Groups of plans” that have the same fiduciaries, plan years, and investments can file a single, combined Form 5500 with (presumably) one audit.