ASPPA Qualified Pooled Plan Professional (QP3) Feed

Question

Under ERISA §3(43), which statutory requirement must be met for a defined contribution retirement plan to qualify as a Pooled Employer Plan (PEP)?

Pooled Plan Structures And Parties

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Question

Which of the following service providers in a Pooled Employer Plan is primarily responsible for holding plan assets in trust and executing settlement transactions?

Pooled Plan Structures And Parties

Question · Easy

Question

Under ERISA §412 and DOL regulations governing Pooled Plan Providers, what fiduciary bonding requirement applies to individuals who handle funds or property of a PEP?

Pooled Plan Structures And Parties

Question · Medium

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Question

Which category of employee benefit plan is statutorily permitted to be structured as a Pooled Employer Plan (PEP) under ERISA §3(43)?

Pooled Plan Structures And Parties

Question · Easy

Question

Under ERISA §3(43)(B) and IRC §413(e), which mandatory provision must be explicitly included in the terms of a Pooled Employer Plan document?

Pooled Plan Structures And Parties

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Question

When an entity serves in dual capacities within a Pooled Employer Plan—acting as both the Pooled Plan Provider and the primary recordkeeper—how must it manage its compensation under ERISA §406(b) and §408(b)(2)?

Pooled Plan Structures And Parties

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Question

Under Department of Labor Advisory Opinion 2012-04A, what is required for a traditional Multiple Employer Plan (MEP) to be treated as a single plan for ERISA Title I reporting purposes (a 'closed MEP')?

Statutory Distinctions

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Question

Prior to the SECURE Act of 2019, how did the Department of Labor treat 'Open MEPs'—arrangements where completely unrelated employers participated in a shared plan without commonality?

Statutory Distinctions

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Question

Under Section 202 of the SECURE Act of 2019, what is a Defined Contribution Group (DCG) / Group of Plans reporting arrangement?

Statutory Distinctions

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Question

How does the annual Form 5500 filing requirement differ between a Pooled Employer Plan (PEP) and a Defined Contribution Group (DCG)?

Statutory Distinctions

Question · Easy

Question

If Corporation A and Corporation B are brother-sister corporations that constitute a controlled group under IRC §414(b) and establish a joint 401(k) plan for all their employees, how is this arrangement classified under ERISA?

Statutory Distinctions

Question · Medium

Question

How does a Professional Employer Organization (PEO) retirement arrangement typically compare to a Pooled Employer Plan (PEP)?

Statutory Distinctions

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Question

Under SECURE 2.0 Act of 2022, how was the scope of Pooled Employer Plans expanded regarding IRC §403(b) tax-sheltered annuity plans?

Statutory Distinctions

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Question

When an adopting employer conducts its periodic review of a Pooled Plan Provider (PPP) under ERISA §404(a), which practice provides the strongest evidence of procedural prudence?

Governance And Fiduciary

Question · Medium

Question

Which of the following actions constitutes a prohibited transaction under ERISA §406(b)(1) in the operation of a Pooled Employer Plan?

Governance And Fiduciary

Question · Medium

Question

Under Department of Labor guidance, when a Pooled Plan Provider has inherent conflicts of interest regarding proprietary investment funds or affiliated service fees, what governance mechanism best protects fiduciaries?

Governance And Fiduciary

Question · Medium

Question

What regulatory enforcement authority does the Department of Labor Employee Benefits Security Administration (EBSA) maintain over Pooled Plan Providers?

Governance And Fiduciary

Question · Easy

Question

When evaluating whether a small business with 25 employees should sponsor a standalone 401(k) plan or join a Pooled Employer Plan (PEP), which factor represents a primary benefit of joining the PEP?

Evaluating Plan Structures

Question · Easy

Question

A growing manufacturing company currently sponsors a standalone 401(k) plan with 130 participants with account balances, paying approximately $15,000 annually for an independent qualified public accountant (IQPA) plan audit. How would joining a Pooled Employer Plan (PEP) impact this audit expense?

Evaluating Plan Structures

Question · Medium

Question

Which trade-off must an employer typically accept when transitioning from a customized standalone 401(k) plan to a Pooled Employer Plan?

Evaluating Plan Structures

Question · Easy

Question

An eligible employer had 30 employees each paid at least $5,000 in 2025. It joins a PEP to establish its first retirement plan in 2026, with 20 non-highly compensated employees eligible to participate and $3,500 in qualified startup administrative costs. What is its maximum 2026 startup-cost credit under IRC §45E?

Evaluating Plan Structures

Question · Hard

Question

Under Section 112 of the SECURE 2.0 Act, how does the military spouse retirement plan tax credit (IRC §45AA) apply to a small employer participating in a Pooled Employer Plan?

Evaluating Plan Structures

Question · Medium

Question

Which of the following restrictions on employer size or employee count applies to an employer seeking to join a Pooled Employer Plan under federal law?

Evaluating Plan Structures

Question · Easy

Question

When benchmarking the total cost of a Pooled Employer Plan for an adopting employer, which fee components must be evaluated together to determine the 'all-in' cost?

Evaluating Plan Structures

Question · Medium

Question

During the formal RFP and due diligence process for selecting a Pooled Plan Provider (PPP), which documentation should an adopting employer's fiduciary committee prioritize reviewing?

Evaluating Plan Structures

Question · Medium

Question

What is the legal function of the Participation Agreement (or Adoption Agreement) executed by an employer entering a Pooled Employer Plan?

Employer Onboarding

Question · Easy

Question

Which of the following plan design elections is typically customizable by an individual adopting employer within a standardized PEP Adoption Agreement?

Employer Onboarding

Question · Medium

Question

When an employer transitions an existing standalone 401(k) plan into a Pooled Employer Plan, what is the primary operational difference between a 'plan merger' (spin-in) and maintaining a legacy plan in run-off?

Employer Onboarding

Question · Medium

Question

When merging a prior standalone 401(k) plan into a Pooled Employer Plan, how does the anti-cutback rule under IRC §411(d)(6) constrain the adoption agreement provisions?

Employer Onboarding

Question · Medium

Question

During an asset transition into a PEP where participants do not provide affirmative investment re-elections, how can fiduciaries obtain fiduciary safe harbor relief for mapped investments under ERISA §404(c)(5)?

Employer Onboarding

Question · Medium

Question

Which employee census data points are critical for an adopting employer to provide to the Pooled Plan Provider during onboarding to ensure correct eligibility and compliance testing?

Employer Onboarding

Question · Easy

Question

An adopting employer replaces its standalone 401(k) plan with participation in a PEP. For vesting under IRC §411(a)(4), which general rule applies to employees' service with that employer before the PEP adoption date?

Employer Onboarding

Question · Medium

Question

An adopting employer in a PEP fails to remit $20,000 in employee salary deferrals for 60 calendar days beyond the DOL timely deposit deadline. How must this failure be corrected under the DOL Voluntary Fiduciary Correction Program (VFCP)?

Contribution Processing Operations

Question · Hard

Question

Under IRS Notice 2025-67, what is the maximum elective deferral limit under IRC §402(g) and the regular age 50+ catch-up contribution limit under IRC §414(v) for calendar year 2026?

Contribution Processing Operations

Question · Easy

Question

A participant participating in an adopting employer's 401(k) plan within a PEP turns age 61 in 2026. Under Section 109 of the SECURE 2.0 Act (IRC §414(v)(2)(E)(i)), what is the maximum total elective deferral amount this participant may contribute in 2026?

Contribution Processing Operations

Question · Medium

Question

If an adopting employer in a PEP elects in its adoption agreement to calculate employer matching contributions on a payroll-by-payroll basis without a true-up provision, how are participant matches affected when an employee front-loads deferrals early in the year?

Contribution Processing Operations

Question · Medium

Question

A PEP's document requires forfeitures attributable to Employer A to remain in its component. Under the IRS's proposed defined contribution forfeiture rules, which use of those forfeitures is permitted, as specified in the plan?

Contribution Processing Operations

Question · Medium

Question

How are required Actual Deferral Percentage (ADP) and Actual Contribution Percentage (ACP) tests conducted for unrelated employers in a Multiple Employer Plan or PEP?