Retirement Plans Newsletter

BULLETIN
August 20, 2020

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[Official Guidance]

Text of DOL Proposed Regs: Registration Requirements for Pooled Plan Providers (PDF)

79 pages. "This proposed rule would establish the requirements for registering with the [DOL] as a 'pooled plan provider' for 'pooled employer plans' under sections 3(43) and 3(44) of [ERISA]. The [SECURE Act] provides that newly permitted 'pooled plan providers' can begin offering 'pooled employer plans' on January 1, 2021, but requires such persons to register with the Secretary of Labor before beginning operations.

"The proposed rule would also establish a new form -- EBSA Form PR (Pooled Plan Provider Registration) -- as the required filing format for pooled plan provider registrations. Filing the proposed Form PR with the [DOL] would also satisfy the SECURE Act requirement to register with the Treasury Department....

"While pooled plan providers will be required to file Forms 5500 for the pooled employer plans they operate, Forms 5500 generally are not filed until seven to nine-and-a-half months after the end of the plan year. In the absence of appropriate detail in the registration statement, a pooled plan provider could begin operating multiple plans with hundreds or thousands of participants and millions of dollars without the agencies having any information about the pooled employer plans for almost two years....

"The proposal would require an initial registration filing and supplemental filings to report changes in the information in the initial filing, information about each specific pooled employer plan before initiation of operations, and information on specified reportable events.... The proposal would require a final filing once the last pooled employer plan has been terminated and ceased operations.

"The Department believes that the initial registration, supplemental filing, and final filing requirements, when combined with the Form 5500 annual reporting requirements, will give the Department the timely access to pooled plan provider information needed to fulfill the monitoring and oversight tasks the SECURE Act placed on the agencies and would be less burdensome and less costly for pooled plan providers and pooled employer plans than some alternatives that were considered."

Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]

DOL Proposes Registration Requirements for Pooled Plan Providers

"EBSA's proposed rule would establish straightforward requirements for pooled plan providers to register with the [DOL]. The proposal, which includes both a mock-up of the required form and the instructions for the form, makes clear in the preamble that the Treasury Department and IRS intend to treat registration with the [DOL] in accordance with the final regulation to satisfy the SECURE Act requirement to register with the Secretary of the Treasury.... The proposal includes a 30-day comment period[.]"

Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]

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Lois Baker, J.D., President  loisbaker@benefitslink.com
David Rhett Baker, J.D., Editor and Publisher  davebaker@benefitslink.com
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