No one who claimed to make me rich ever did. No person who had thousands of potential clients for a PEP really scored more than 1% of what they thought they could get.

The road to hell is paved with good intentions, as well as any PEP opportunity that plan providers think they have. January 1 will mark two years of Pooled Employer Plans (PEPs). Thanks to poor traction, lack of participants, and high fees, I expect more PEPs to fail. I worked with one client where they couldn’t get a PEP off the ground with even just one adopting employer.

Expect PEPs to fold or merge into a bigger PEP. Two of the PEPs I’m affiliated with will be like the New Colossus poem on the Statute of Liberty, where plan providers could dump their tired, poor, huddled PEPs, yearning to be free.