"In the good old days, if you had more than 100 or 120 participants, as applicable, you had a large plan -- AUDIT REQUIRED! Pursuant to the SECURE ACT, however, starting on January 1, 2021, a group of Small Plans can band together in one Pooled Employer Plan (PEP) and still escape the audit requirement, but only until the total number of participants in the PEP reaches 1,000 (or one of the Small Plans becomes a Large Plan)."