DOL issues PEP Rule

Ary Rosenbaum - The Rosenbaum Law Firm P.C.
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Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Department of Labor has finally announced a final rule establishing registration requirements for pooled plan providers under the SECURE Act.

The SECURE Act established the pooled employer plan (PEP). Pooled employer plans must be administered by a “pooled plan provider.”

The SECURE Act allows pooled plan providers to start operating pooled employer plans beginning on Jan. 1, 2021 but requires that pooled plan providers register with the Secretary of Labor and the Secretary of the Treasury before they begin operations as a pooled plan provider.

The final rule establishes a straightforward electronic registration for entities that want to operate as a pooled plan provider. Except for the period of Nov. 25, 2020, to Jan. 31, 2021, the process will require pooled plan providers to register at least 30 days before beginning operations.

Registration with the Department of Labor will satisfy the requirement to register with the Secretary of the Treasury.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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