News & Analysis as of

Benefit Plan Sponsors Retirement Plan Providers Multiple Employer Plan (MEP)

Patterson Belknap Webb & Tyler LLP

Pooled Employer Plans: DOL Issues New Interpretive Guidance and Tips for Employers

On July 29, 2025, the Department of Labor (the “DOL”) published limited interpretive guidance regarding pooled employer plans, or “PEPs,” in the Federal Register (the “New Guidance”). Although PEPs are available to all sizes...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Well, I have an in with this association

If I got $5 for every time an advisor or other plan provider told me they had an in with an association, I’d probably have enough to pay my mortgage. The problem. Having an in doesn’t mean that advisor or plan provider can...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The PEP Gold Rush

I like choice and I like the idea that there is something called Pooled Employer Plans (PEPs) in 2021 because I always liked the idea of Open Multiple Employer Plans (MEPs). Another great aspect of it is the discussion and...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

I’ve seen how this story played out

As everyone is gearing for the January 1, 2021 implementation of pooled employer plans (PEPs), I keep on insisting that this won’t be the game-changer that everyone hopes. I think PEPs are a great idea, it finally...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The State Auto-Enroll IRA Plans are a good thing

Colorado is just another state that is offering a payroll deduction IRA program, forcing businesses to offer this program if they have five or more employees. I’m in favor of anything that offers increased retirement plan...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

You can’t sell Betamax in a world of VHS

A plan provider once asked me if I had written a full-blown article on why trustee directed 401(k) plans are better than participant-directed plans. I haven’t even if I believed in it (which I do), but it’s not going to get...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Fear About PEPs

I am a proponent of multiple employer plans (MEPs) and the new change that will allow pooled employer plans (PEPs) that will be what we called an Open MEP in 2021. As discussed in other posts, the PEP change doesn’t change...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Per head charges are eye popping in MEP case

National Rural Electric Cooperative Association (NRECA) is a national service organization that represents more than 1,000 rural electric cooperatives around the United States. NRECA sponsors a 401(k) multiple employer plan...more

Faegre Drinker Biddle & Reath LLP

SECURE Act and Guaranteed Income (Part 1)

There are two parts of the SECURE Act that I believe will have the greatest impact on plan sponsors and service providers. • The first part includes the provisions on retirement income, including the safe harbor for...more

Schwabe, Williamson & Wyatt PC

New Retirement Plan Legislation Enacted Into Law

On December 20, 2019, federal legislation approving spending limits for the 2020 fiscal year was signed into law. Included in the legislation is the Setting Every Community Up for Retirement Enhancement Act of 2019 (the...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Open MEPs will eventually rise again

Multiple employer plans (MEPs) are a topic that many plan providers talk about, but don’t really know what’s allowed and what’s not. A multiple employer plan is a plan where unrelated employers adopt a plan and it should...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Plan Sponsors Sued Over Fees on Multiple Plans and Vendors

In a very novel retirement fee lawsuit, a plan sponsor is being sued over the cost of multiple plans and the use of multiple record-keepers....more

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