Registration Requirements to Serve as a Pooled Plan Provider to Pooled Employer Plans

The Setting Every Community Up for Retirement Enhancement Act of 2019 (the SECURE Act) was designed to improve retirement coverage as well as the ability of individuals to manage important retirement-related risks. Specifically, the Secure Act requires Section 101 of the SECURE Act requires a “pooled plan provider” to register with the Labor Department and the Treasury Department before beginning operations as a pooled plan provider. Specifically, Section 101 of the SECURE Act amends section 3(2) of the Employee Retirement Income Security Act (ERISA) to eliminate the commonality of interest requirement for establishing certain individual account plans, or “pooled employer plans,” that meet specific requirements. Among these requirements, plans must designate a “pooled plan provider” to serve as a named fiduciary and as the plan administrator. Further, section 101 of the SECURE Act requires pooled plan providers to register with the Department of Labor (the Department) and the Department of the Treasury (Treasury) before beginning operations. The statute expressly provides a separate authorization for the Department to require additional information.

The latest form for Registration Requirements to Serve as a Pooled Plan Provider to Pooled Employer Plans expires 2023-11-30 and can be found here.