I learned one of the biggest concerns was “Can my company leave the MEP if things change?” The simple answer is yes. Of course, as with most answers, it all depends on the specifics of the particular plan design. (Photo: Shutterstock)
No fancy prose this week. No pop culture allusions. Just the straight dope. But first, a disclosure: Besides reporting on this subject for some time now, several years ago, I helped a business association create a 401(k) MEP or multiple employer plan. I worked with several different service providers and researched plenty more. This was not an “Open MEP,” but a true MEP. Unlike Open MEPs, in a true MEP the underlying plans were not required to continue to operate as if they were a separate plan.
Within the last month, two things have occurred which have spurred concentrated interest in MEPs. The DOL has acted on President Trump's executive order and submitted their MEP proposal to the OMB. In addition, there has been a legitimate push in Congress towards broadening the definition of “true MEP” to include Open MEPs. Now more than ever, companies want to know more about the MEP (see “What Every Company 401k Plan Fiduciary Needs to Know about MEPs,” FiduciaryNews.com, September 25, 2018).
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