PLANSPONSOR - May/June 2024 - 10

UPFRONT
Can MEPs and PEPs Close the Gap?
AS ONLY about half of U.S. private sector
workers are covered by an employer-sponsored
retirement plan at any given time,
inadequate coverage is a major threat to
the nation's retirement income security.
This lack of access to a workplace
retirement plan is largely driven by small
employers, which often cannot afford
to sponsor their own plan or take on the
administrative burden of managing one.
Origins of MEPs, PEPs
To lower plan sponsorship costs for small
employers, and thereby reduce the coverage
gap, the Setting Every Community Up for
Retirement Enhancement Act of 2019
made multiple employer plans less restrictive
and potentially more attractive to this
employer segment.
As explained in a paper by the Center
for Retirement Research at Boston
College, unlike single-employer plans,
a MEP is a plan adopted by two or more
employers and administered by a MEP
sponsor. A MEP can be either a defined
benefit or a defined contribution plan,
but most are 401(k)-type DC plans. By
allowing employers to offer a plan jointly,
the MEP sponsor assumes fiduciary
responsibility and spreads the administrative,
compliance and cost burdens across
multiple employers.
Employers participating in a MEP
still have fiduciary responsibility, but it
is limited to selecting and overseeing the
person or entity operating the plan.
Anqi Chen, a senior research economist
at CRR, says MEPs have been around
for a long time-they were authorized by
the Labor Relations Act of 1947, but the
SECURE Act made them more widely
available. Still, they have yet to " move the
needle, " she says, in terms of expanding
retirement plan coverage.
" Among the many other things a
small business has to consider, offering
a retirement plan is just not very high on
its list, " Chen says.
10 PLANSPONSOR.COM May - June 2024 Art by Nadja Zinnecker
Two of the main restrictions that
initially limited the adoption of MEPs
were
the
requirement
that employers
had to share a " common bond " and that
the whole MEP could lose its tax-qualified
status if one employer within the
group was out of compliance-otherwise
known as the " bad apple " rule.
The SECURE Act removed the bad
apple restriction if certain requirements
were met. It also authorized pooled
employer plans, which are open to
employers with no common bond.
PEPs may be established only by
a pooled plan provider, and that entity
takes on the role of named fiduciary,
overseeing plan administration, compliance
and auditing.
'Keeping an Eye' on the PPP
Although the PPP assumes most of the
PEP's fiduciary duties, Chen says, the
employers still have to " keep an eye " on
the provider, as with a MEP, to ensure its

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PLANSPONSOR - May/June 2024

Table of Contents for the Digital Edition of PLANSPONSOR - May/June 2024

Insights
The Proactive Adviser
Mastering the In-Plan Annuities
2024 Plan Sponsor of the Year Finalists
Why a Second Committee?
Savings Need to Last
DOL Finalizes QPAM Exemption
Filing a VFC Application?
Careful Consideration
PLANSPONSOR - May/June 2024 - Cover1
PLANSPONSOR - May/June 2024 - FC1
PLANSPONSOR - May/June 2024 - FC2
PLANSPONSOR - May/June 2024 - Cover2
PLANSPONSOR - May/June 2024 - 1
PLANSPONSOR - May/June 2024 - Insights
PLANSPONSOR - May/June 2024 - 3
PLANSPONSOR - May/June 2024 - 4
PLANSPONSOR - May/June 2024 - 5
PLANSPONSOR - May/June 2024 - 6
PLANSPONSOR - May/June 2024 - 7
PLANSPONSOR - May/June 2024 - 8
PLANSPONSOR - May/June 2024 - 9
PLANSPONSOR - May/June 2024 - 10
PLANSPONSOR - May/June 2024 - 11
PLANSPONSOR - May/June 2024 - 12
PLANSPONSOR - May/June 2024 - 13
PLANSPONSOR - May/June 2024 - 14
PLANSPONSOR - May/June 2024 - 15
PLANSPONSOR - May/June 2024 - 16
PLANSPONSOR - May/June 2024 - 17
PLANSPONSOR - May/June 2024 - The Proactive Adviser
PLANSPONSOR - May/June 2024 - 19
PLANSPONSOR - May/June 2024 - 20
PLANSPONSOR - May/June 2024 - 21
PLANSPONSOR - May/June 2024 - Mastering the In-Plan Annuities
PLANSPONSOR - May/June 2024 - 23
PLANSPONSOR - May/June 2024 - 24
PLANSPONSOR - May/June 2024 - 25
PLANSPONSOR - May/June 2024 - 2024 Plan Sponsor of the Year Finalists
PLANSPONSOR - May/June 2024 - 27
PLANSPONSOR - May/June 2024 - 28
PLANSPONSOR - May/June 2024 - 29
PLANSPONSOR - May/June 2024 - 30
PLANSPONSOR - May/June 2024 - 31
PLANSPONSOR - May/June 2024 - 32
PLANSPONSOR - May/June 2024 - 33
PLANSPONSOR - May/June 2024 - Why a Second Committee?
PLANSPONSOR - May/June 2024 - 35
PLANSPONSOR - May/June 2024 - Savings Need to Last
PLANSPONSOR - May/June 2024 - 37
PLANSPONSOR - May/June 2024 - DOL Finalizes QPAM Exemption
PLANSPONSOR - May/June 2024 - Filing a VFC Application?
PLANSPONSOR - May/June 2024 - Careful Consideration
PLANSPONSOR - May/June 2024 - Cover3
PLANSPONSOR - May/June 2024 - Cover4
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https://www.plansponsordigital.com/plansponsor/may_june_2024
https://www.plansponsordigital.com/plansponsor/march_april_2024
https://www.plansponsordigital.com/plansponsor/january_february_2024
https://www.plansponsordigital.com/plansponsor/november_december_2023
https://www.plansponsordigital.com/plansponsor/september_october_2023
https://www.plansponsordigital.com/plansponsor/july_august_2023
https://www.plansponsordigital.com/plansponsor/excellenceawards_2023
https://www.plansponsordigital.com/plansponsor/may_june_2023
https://www.plansponsordigital.com/plansponsor/march_april_2023
https://www.plansponsordigital.com/plansponsor/december_2022_february_2023
https://www.plansponsordigital.com/plansponsor/october_november_2022
https://www.plansponsordigital.com/plansponsor/august_september_2022
https://www.plansponsordigital.com/plansponsor/june_july_2022
https://www.plansponsordigital.com/plansponsor/excellenceawards_2022
https://www.plansponsordigital.com/plansponsor/april_may_2022
https://www.plansponsordigital.com/plansponsor/february_march_2022
https://www.plansponsordigital.com/plansponsor/december_2021_january_2022
https://www.plansponsordigital.com/plansponsor/october_november_2021
https://www.plansponsordigital.com/plansponsor/august_september_2021
https://www.plansponsordigital.com/plansponsor/june_july_2021
https://www.plansponsordigital.com/plansponsor/april-may_2021
https://www.plansponsordigital.com/plansponsor/february-march_2021
https://www.plansponsordigital.com/plansponsor/december-january_2021
https://www.plansponsordigital.com/plansponsor/october-november_2020
https://www.plansponsordigital.com/plansponsor/august-september_2020
https://www.plansponsordigital.com/plansponsor/june-july_2020
https://www.plansponsordigital.com/plansponsor/april-may_2020
https://www.plansponsordigital.com/plansponsor/february-march_2020
https://www.plansponsordigital.com/plansponsor/december-january_2020
https://www.plansponsordigital.com/plansponsor/october-november_2019
https://www.plansponsordigital.com/plansponsor/august-september_2019
https://www.plansponsordigital.com/plansponsor/june-july_2019
https://www.plansponsordigital.com/plansponsor/april-may_2019
https://www.plansponsordigital.com/plansponsor/february-march_2019
https://www.plansponsordigital.com/plansponsor/december_2018-january_2019
https://www.plansponsordigital.com/plansponsor/october-november_2018
https://www.plansponsordigital.com/plansponsor/august-september_2018
https://www.plansponsordigital.com/plansponsor/june-july_2018
https://www.plansponsordigital.com/plansponsor/april-may_2018
https://www.plansponsordigital.com/plansponsor/february-march_2018
https://www.plansponsordigital.com/plansponsor/december_2017-january_2018
https://www.plansponsordigital.com/plansponsor/november_december_2017
https://www.plansponsordigital.com/plansponsor/october_2017
https://www.plansponsordigital.com/plansponsor/september_2017
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