As Pooled Employer Plans (PEPs) gain traction, many employers are asking a key question.
How robust is the investment strategy behind the retirement plan?
While PEPs streamline administration and reduce fiduciary burden, long-term participant outcomes are shaped by the quality of the PEP investment strategy, not just operational efficiency.
Here, Meghan Hannon, CRPS®, CPFA®, Partner and Head of Retirement Plan Consulting, outlines how governance, fund selection and monitoring can come together to shape a resilient PEP investment strategy—and how employers can assess whether a PEP aligns with their needs and fiduciary expectations.
How PEP Investment Governance and Fiduciary Oversight Work
Unlike traditional single-employer plans, PEPs centralize investment decision-making. In most PEP structures, the Pooled Plan Provider (PPP) serves as the named fiduciary and selects an ERISA Section 3(38) discretionary investment manager to assume responsibility for investment selection, monitoring and replacement. This model represents the predominant approach in the PEP marketplace.
While it is possible for a PEP to utilize a non-discretionary ERISA Section 3(21) investment advisor, this structure is less common and leaves more investment fiduciary responsibility with the PPP and participating employers.
High-quality PEPs maintain an Investment Policy Statement (IPS) that outlines how investments are selected, monitored and replaced over time. Employers should understand the governance model well enough to maintain oversight without taking on day-to-day responsibilities.
What to look for:
- Who has discretion over investment decisions (PPP, 3(38), or 3(21))
- Frequency and format of performance reviews
- Watch-list criteria and replacement protocols
- How fund changes are communicated to employers and participants
- Document fee oversight and share-class rationale
Evaluating PEP Investment Lineups and Fund Selection
The design of a PEP’s investment lineup directly impacts participant outcomes. Most well-constructed PEPs offer a mix of:
- Core equity and fixed income options
- Asset allocation vehicles such as target date or balanced funds
- Specialty funds, which may include ESG-focused or real-assets exposure
PEPs may use Collective Investment Trusts (CITS), mutual funds, separate accounts or ETFs. The key is a disciplined PEP fund selection process that balances simplicity, diversification and cost efficiency. Employers should look for evidence of rigorous monitoring and consistency of investment style.
Choosing the Right QDIA for Your PEP Investment Strategy
In most PEPs, the Qualified Default Investment Alternative (QDIA)—often a target date fund (TDF)—captures a significant portion of plan assets, though the extent can vary based on plan demographics, enrollment design, and how long the plan has been in operation. Because automatic enrollment and participant inertia drive allocation, the QDIA largely defines the investment experience for many employees.
Evaluating a QDIA requires considering glide path design, diversification, underlying fund quality and fees. Some PEPs offer custom or white-labeled target date solutions designed for the plan’s specific participant demographics. Alignment with participant needs is more important than complexity.
Monitoring Performance of Pooled Employer Plan Investments
Although the PEP provider is responsible for day-to-day monitoring, employers should expect transparent reporting. Effective monitoring includes quarterly performance summaries, watch-list updates, and clear expectations for fund changes. This process ensures confidence in the PEP investment strategy.
Balancing Cost and Quality in PEP Investment Options
A successful PEP investment strategy blends governance, fund selection, cost management and participant education. Employers should focus on:
- Clear governance and documented fiduciary responsibilities
- Diversified fund lineups with effective default options
- Transparent monitoring and reporting
- Thoughtful balance between cost and investment quality
Ready to evaluate your investment strategy?
Connect with us to review your strategy and determine whether the RetireNAV(k) PEP is the right fit for your organization.