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Since the Department of Labor issued their 2012 guidance on “open MEPs,” there have been many unanswered questions and pressure for more guidance. Open MEPs are a series of separate plans under ERISA, not a single ERISA plan. However, “closed” MEPs can still be treated as single plans under ERISA. The so-called “one bad apple rule” creates risks to participating employers, but MEPs have many potential administrative and cost advantages over single-employer plans.
The President, Congress, and the Department of Labor have all recently weighed in on the potential benefits of, and the need for changes to MEPs, and Congress has proposed the creation of Pooled Employer Plans (PEPs) as an alternative. So far, both the DOL and IRS have proposed guidance, but these steps raise their own concerns. While the timing is uncertain, the SECURE Act looks likely to bring more changes to this landscape. This seminar will review the current status of the MEPs and PEPs.
Topics include:There are no prerequisites or other advanced preparation for this program. However, the speaker will assume that attendees understand the operation of 401(k) plans in general and have one year of experience. The speaker will not assume prior experience with multiple employer plans.
Level: IntermediateNASBA Field of Study: Taxes
Speaker: David Schultz, J.D.Objectives: After attending this Web seminar, attendees should be able to:
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