"It's not the plan structure that led to the theft, it was the criminal who was running the plan.... [H]ad the [DOL] not been brought into the Hutcheson case at the exact same time they were weighing Toth's request, multiple employer plans would be the dominant retirement plan structure for smaller employers across the United States today.... The [DOL] needs to rescind DOL AO-2012-04A and replace it with guidance that incorporates the spirit of the proposed legislation ... Congress needs to continue their work to establish Pooled Employer Plans, which will be overseen by registered Pooled Plan Providers beginning in 2021."