Modifications to Pooled Employer Plans

Updated by Richard Phillips, EA, AIFA, CPC, CPFA, QPA, QKA

The Pooled Employer Plan document requirements were modified by SECURE 2.0 §105 to require a designated fiduciary. The deisgnated fiduciary cannot be a participating employer, and is responsible for collecting contributions to the plan and implementing written contribution collection procedures that are

  • reasonable
  • diligent
  • systematic

The designated named fiduciary must be a bank, insurance company, trust company or other entity approved by the IRS to be a trustee and hold the plan's assets.


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