Key Takeaways
- A Pooled Employer Plan (PEP) provider strengthens retirement plan management through centralized administration and fiduciary oversight
- Core responsibilities include serving as the pooled employer plan provider (PPP), managing compliance, coordinating investments, and supporting participating employers
- The right PEP provider helps employers offer competitive retirement benefits with confidence
What is a PEP and Who Is the Pooled Plan Provider?
Under the SECURE Act of 2019, a Pooled Employer Plan (PEP) allows unrelated employers to participate in a single defined contribution retirement plan. The pooled plan provider (PPP) serves as the named fiduciary and plan administrator, assuming primary responsibility for plan oversight, compliance and coordination. This centralized structure reduces complexity for participating employers while strengthening governance.
What are the fiduciary responsibilities of a PEP provider under ERISA?
A PEP provider serves as the plan’s named fiduciary under the Employee Retirement Income Security Act (ERISA), meaning it must act in the best interests of plan participants and beneficiaries.
Core fiduciary responsibilities include:
- Overseeing plan administration and operations
- Monitoring service providers
- Ensuring adherence to ERISA standards
- Managing plan governance and documentation
Unlike a traditional 401(k), where the adopting employer bears full fiduciary responsibility for plan governance, investment oversight, and compliance, a PEP fundamentally shifts that burden to the PEP provider, allowing employers to participate in a professionally managed plan without carrying the weight of plan sponsorship.
How Does a PEP Provider Ensure Retirement Plan Compliance?
Compliance is a central responsibility of a pooled plan provider. The provider ensures the PEP satisfies IRS and Department of Labor requirements.
Key compliance functions include:
- Filing Form 5500
- Coordinating plan audits, when applicable
- Maintaining operational compliance with plan documents
- Implementing required regulatory updates
By centralizing compliance management, a PEP provider promotes consistency and operational efficiency.
How Does a PEP Provider Manage Investments and Service Providers?
PEP providers oversee investment selection and monitoring, often working with investment advisors and recordkeepers to maintain prudent investment governance.
Responsibilities may include:
- Conducting investment due diligence
- Monitoring performance and fees
- Coordinating third-party administrators and custodians
- Managing payroll and recordkeeping integrations
This coordinated oversight supports strong plan operations and participant outcomes.
What Role Do Employers Still Play in a Pooled Employer Plan?
While the pooled plan provider (PPP) assumes primary fiduciary and administrative responsibility, participating employers retain important duties within the plan.
One of the most critical responsibilities is selecting a qualified PPP. Choosing the right provider is itself a fiduciary act, requiring employers to evaluate the PPP’s experience, capabilities, and ability to administer the plan in participants’ best interests.
In addition, employers typically remain responsible for:
- Providing accurate payroll data
- Determining employee eligibility
- Remitting contributions in a timely manner
A strong PEP structure clearly defines these roles, helping reduce uncertainty, reinforce accountability, and support effective plan governance.
How Can RetireNAV(k) Support Your Retirement Strategy?
Boulay’s RetireNAV(k), a Pooled Employer Plan, was designed to simplify retirement plan management, while enhancing oversight and compliance confidence. By centralizing administration and governance, RetireNAV(k) helps employers focus on supporting their workforce—not navigating regulatory complexity.
If your organization is evaluating retirement plan options, Boulay’s specialists can help determine whether RetireNAV(k) aligns with your goals.