It is amazing that with the advent of Pooled Employer Plans (PEPs) just a few weeks away, there is still a great unknown.

We just got the registration requirement down pat and that’s about it. One of the great unknowns is any prohibited transaction issues if one of the current plan providers takes on the role of the pooled plan provider. Will there be exemptions made?

I’m sure the pandemic played a part in this strange rollout, but we usually get more concrete rules in place before all of us in this industry take a big step towards something new.