Things I Worry About (27): Pooled Employer Plans and DOL RFI (8)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that includes questions designed to assist the DOL in developing future guidance about PEPs. Some of those questions suggest that the DOL is concerned about conflicts of interest in the organization and management of PEPs. This article continues a discussion of the questions asked by […]
Things I Worry About (26): Pooled Employer Plans and DOL RFI (7)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that includes questions designed to assist the DOL in developing future guidance about PEPs. Some of those questions suggest a possible fiduciary safe harbor for small employers who adopt PEPs. This article continues a discussion of the questions asked by the DOL and my comments […]
Things I Worry About (25): Pooled Employer Plans and DOL RFI (6)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that includes questions designed to assist the DOL in developing future guidance about PEPs. Some of those questions suggest a possible fiduciary safe harbor for small employers who adopt PEPs. This article begins a discussion of the questions asked by the DOL and my comments […]
Things I Worry About (24): Pooled Employer Plans and DOL RFI (5)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that provides tips for adopting employers and questions about PEPs and that suggests a possible fiduciary safe harbor for small employers who adopt PEPs. This article continues a discussion of the questions that the DOL says that employers should ask when considering adopting a PEP […]
Things I Worry About (23): Pooled Employer Plans and DOL RFI (4)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that provides tips for adopting employers and questions about PEPs and that suggests a possible fiduciary safe harbor for small employers who adopt PEPs. This article continues a discussion of the questions that the DOL says that employers should ask when considering adopting a PEP […]
Things I Worry About (22): Pooled Employer Plans and DOL RFI (3)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that provides tips for adopting employers and questions about PEPs and a possible fiduciary safe harbor for small employers who adopt PEPs. This article begins a discussion of the questions that the DOL says that employers should ask when considering adopting a PEP for their […]
Things I Worry About (21): Pooled Employer Plans and DOL RFI (2)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that provides tips for adopting employers and questions about PEPs and a possible fiduciary safe harbor for small employers who adopt PEPs. In addition, the preamble to the guidance includes some interesting information about the development of PEPs. That information includes data about the successes […]
Things I Worry About (20): Pooled Employer Plans and DOL RFI (1)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that provides tips for adopting employers and questions about PEPs and a possible fiduciary safe harbor for small employers who adopt PEPs. In addition, the preamble to the guidance includes some interesting information about the development of PEPs. This series of articles examines the DOL’s […]
Things I Worry About (6): Automatic Enrollment (5) and PEPs
Key Takeaways The SECURE Act 2.0 required that “new” 401(k) and private sector 403(b) plans automatically enroll their eligible employees, but not until plan years beginning after December 31, 2024…just days ago. “New” plans include most that were established on or after the enactment date of SECURE 2.0—December 29, 2022. “Old” plans—those adopted before the […]