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Multiple Changes for Multiple Employer Plans
Morgan Lewis Link to more items from this source
[Guidance Overview]
Oct. 11, 2019

"These regulations help alleviate some of the uncertainty and risk that have made MEPs unpopular in recent years, but a number of questions remain unanswered.... Will the DOL issue subsequent regulations that permit financial institutions to sponsor MEPs on behalf of related or unrelated employers? How safe are the DOL's final regulations on MEPs now that a court has vacated the DOL's final regulations on association health plans (which used a nearly identical interpretation of the term 'employer' under ERISA)? ... What fiduciary exposure does an MEP administrator have where it spins off assets attributable to a noncompliant employer's employees, without the consent of such employer and in accordance with the proposed IRS regulations?"

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