"[T]he new PEP rules do not add any new services to the marketplace. Rather, PEPs merely reorganize existing services to be provided in a different format, with the one exception is that it now permits unrelated employers to be able to file a consolidated Form ... [T]he Department's issuance of guidance as to the allocation of these different authorities ... is a required condition precedent to the determination of whether any prohibited transaction exemptive relief is necessary in the operation of a PEP."  MORE >>