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3(16) Plan Customer Liaison, Enrollments Compass
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Free Publications
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Employee Aggregation Rules: Affiliated Service Groups
Employee Benefits Law Group 
[Guidance Overview] June 12, 2026 "Each of the first two ASG rules requires some degree of overlapping ownership and at least one of the organizations must be involved principally in the performance of services. Generally, an organization will not be considered a service organization if capital is a material income-producing factor (e.g., a substantial portion of the gross income of the business is attributable to investment in inventories, plant, machinery, or other equipment)." MORE >> |
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