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SPARK Comment Letter to EBSA on Prohibited Transactions Involving Pooled Employer Plans Under the SECURE Act and Other Multiple Employer Plans (PDF)
The SPARK Institute 
[Opinion] July 21, 2020 "[T]he SPARK Institute's comments: [1] discuss some general principles that should guide the Department in formulating guidance under the SECURE Act; [2] provide an overview of the business models that firms are currently considering to make PEPs available; [3] discuss the conflicts of interest and prohibited transaction issues that are relevant to PEPs and MEPs; and [4] highlight a specific need for guidance on the SECURE Act's requirement for PEP trustees to be responsible for collecting PEP contributions." |
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