In today's changing retirement plan marketplace, finding an independent fiduciary is challenging. In recent years, as more firms have begun to offer some level of fiduciary services, Fiduciary Consulting Group has maintained its independence. This allows our firm to best serve our clients on any service provider's platform that is most appropriate for their business, staff, and retirement plan participants.
Fiduciary Consulting Group serves PEO and association retirement plans by accepting the roles of 3(16) Plan Administrator and 402 Named Fiduciary. This provides a greater level of protection to the organization or association and allows these entities to focus on their primary business of serving customers or members. Our experience and management protocols, along with our high-touch service model, enhances the value proposition of the PEO or association in their benefits offering, specifically in having the retirement plan managed by an Independent Fiduciary.
Several years ago, the Department of Labor made changes that eliminated non-related employers from joining together under one plan, previously known as an open multiple employer plan (MEP). With the passage of the Secure Act in December of 2019, non-related employers can now once again join together in a pooled employer plan (PEP) arrangement. There are several specific fiduciary responsibilities that employers now have when a decision is made to join a PEP.
A pooled employer plan (PEP) is a defined contribution plan qualified under Code Section 401(a) or a plan consisting of individual IRA accounts that uses a Pooled Plan Provider (PPP) and satisfies all the plan documents and other requirements to be a PEP. [SECURE Act §§ 101(a) and (c)]
Pooled Employer Plans (PEPs) are the new platforms that are available for non-related employers to join together under one plan. PEPs must select a pooled plan provider (PPP) to be the fiduciary over the plan and serve as the Plan Administrator.
As challenging as it has been in recent years, in understanding the different levels of 3(16) "fiduciary services" that are being offered, so to will the understanding of the responsibilities of these PPPs and the risk of engaging one with limited or no experience as a fiduciary.
A pooled plan provider (PPP) is a new type of service provider Congress has defined that can offer a pooled plan with no commonality among participating employers and have it treated as a single ERISA plan. [SECURE Act § 101(c)]
There are no restrictions on the type of entity that can be a PPP.
There are several other alternatives to PEPs. However, with the PEP being the "shiny new object," they are currently getting all the attention. Our firm can help employers / plan sponsors, retirement plan advisers, and industry service providers aggregate employers for business scale and profitability in either a MEP, PEP, or one of the other viable solution available today.
Please contact our firm for more information.
Fiduciary Consulting Group, Inc.
P O Box 11408, 1832 Ward Drive, Suite 101, Murfreesboro, TN 37129
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