"Congress adopted the SECURE Act to expand the ability of small employers, including self-employed individuals, to participate in pooled employer plans and benefit from the economies of scale such plans provide. Accordingly ... it is reasonable to similarly treat pooled employer plans as single employer plans for purposes of rule 180(a)(2).... [T]he staff would not object if a CIT issues interests to a pooled employer plan that covers self-employed persons without registering the offer and sale of the CIT's interests under section 5 of the Securities Act in reliance on rule 180; provided that the plan: [1] is subject to ERISA; and [2] the issuance meets all of the requirements in rule 180(a)(1) and (a)(3)."  MORE >>