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Pooled Employer Plans: Where Do We Stand? (PDF)
ASC
[Guidance Overview] Sept. 25, 2020 "Except for proposed rules regarding the registration requirement, the IRS and DOL have not provided guidance on the PEP and PPP rules.... The registration rules are quite extensive (79 pages) and would require significant disclosures by the PPP.... Although the IRS has not officially announced that pre-approved plans will be allowed to include PEP provisions, ASC expects this will be permitted ... Our understanding is that the IRS is working on this model plan language, but it has not provided an expected issuance date." |
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