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Things to Worry About, Part 23: Pooled Employer Plans and DOL RFI
FredReish.com 
[Guidance Overview] Oct. 21, 2025 "[W]here the PPP appoints the investment manager, the PPP is the fiduciary responsible for the selection and monitoring of the 3(38) investment manager. However, the law says that adopting employers are responsible determining if the 'named fiduciaries' are prudent choices for its participating employees.... That raises the question of the scope of the fiduciary duty of adopting employers related to the investment manager -- since the adopting employers cannot remove and replace an investment manager selected by the PPP." MORE >> |
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