J Simmons Posted February 12, 2007 Posted February 12, 2007 Is a MEP with one trust to hold benefits of the employees of the different, unrelated employers subject to securities laws registration if no trust assets are invested in securities of any of the participating employers? Or is there a securities law exemption where no employer securities are involved? John Simmons johnsimmonslaw@gmail.com Note to Readers: For you, I'm a stranger posting on a bulletin board. Posts here should not be given the same weight as personalized advice from a professional who knows or can learn all the facts of your situation.
QDROphile Posted February 12, 2007 Posted February 12, 2007 A multiple employer plan is not exempt from registration even if it does not invest in any employer securities. If the plan allows employee deferrals or contributions, it has to deal with lack of the usual exemption.
J Simmons Posted February 12, 2007 Author Posted February 12, 2007 Thanks, QDROphile. What about a multiple employer DB plan that has no employee contributions? John Simmons johnsimmonslaw@gmail.com Note to Readers: For you, I'm a stranger posting on a bulletin board. Posts here should not be given the same weight as personalized advice from a professional who knows or can learn all the facts of your situation.
QDROphile Posted February 12, 2007 Posted February 12, 2007 Generally no registration is required, but the arrangement should be evaluated by someone who understands the rules and issues.
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