Expansion of Retirement Plan Options through PEPs and MEPs
Summary
SIFMA provided comments to the Employee Benefits Security Administration (EBSA) in response to the Department of Labor’s request for information with regard to the expansion of retirement plan options through pooled employer plans (PEPs) and multiple employer plans (MEPs).
SIFMA supports the DOL moving this issue forward by working on a prohibited transaction exemption that would expand the availability of these plans for small employers, and provide a wide variety of providers from which to choose.
Excerpt
July 20, 2020
Assistant Secretary Jeanne Wilson
Employee Benefits Security Administration
Department of Labor
200 Constitution Ave., NW
Washington, DC 20210
Re: Z-RIN 1210-ZA28
Dear Secretary Wilson:
The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to respond to the Department of Labor’s (the “Department”) request for information with regard to the expansion of retirement plan options through pooled employer plans (PEPs) and multiple employer plans (MEPs). We strongly support the Department moving this issue forward by working on a prohibited transaction exemption that would expand the availability of these plans for small employers, and provide a wide variety of providers from which to choose.
Our members are also very interested in the other guidance that the Department is required to provide with regard to PEPs/MEPs, including the Pooled Plan Provider (“PPP”) registration requirements, the Form 5500 requirements, PEP audit requirements and other important issues. Many potential providers are unwilling to commit to the resources required to offer these programs without that additional guidance in place. Accordingly, we urge the Department to propose guidance as soon as possible so that they can have an opportunity to review the proposals and comment on them before they become final.2
1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.
2 In addition, the Treasury/IRS should move forward with regard to its proposal with regard to MEPs and the Unified Plan Rule. A proposal was published July 3 2019, 84 FR 31777, with final comments submitted in October 2019.