The Internal Revenue Service (IRS) in their January 20, 2021 edition of Employee Plans News opined that pre-approved qualified retirement plan documents may be used to establish arrangements known as pooled employer plans or PEPs.
The IRS stated that it’s creating a language that can be used to amend current pre-approved qualified retirement plan documents to add a PEP feature. Document providers are not required to use IRS-drafted amendment language, but if drafting their own they “will not have a reliance on those provisions,” the IRS states.
As someone who drafts PEP plan documents, using pre-approved plans, it is nice to hear from the IRS on this. However, the plan document provider I’m using, already drafted an amendment for PEPs.