Pooled Employer Plans (PEPs) are an attractive opportunity for small plans to mitigate the liability and hassle of a plan of their own.

Many PEPs, including some that I run, were budgeted as if there would be no required audit until the plan had 1,000 participants with account balances. The Department of Labor had other plans and no0w requires PEPs with 100 or more participants with an account balance to have an audit. That $10k to $20k cost of an unexpected audit will lead to some PEPs shutting down their doors.