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Pooled Plan Provider NPPG Announces SEC Registration The company believes registration is required and prudently protects clients
Shrewsbury, NJ July 9, 2024 – NPPG Plan Professionals, LLC (NPPG), an industry-leading Pooled Plan Provider in the pooled employer plan space announced it has successfully met the required prerequisites and has registered as an investment adviser with the Securities and Exchange Commission (SEC). NPPG currently serves as PPP for 20 Pooled Employer Plans (PEPs) that collectively hold billions of dollars in plan assets. NPPG considers such SEC registration to be both required and the most prudent way to protect client interests when a PPP’s role and responsibilities encompass both administrative and investment fiduciary activities of the plan.
Since 2020, approximately 70 entities have registered with the Department of Labor as Pooled Plan Providers, of which about 40 offer some combination of investment management, investment advice, and investment products.1 It is understood that PPPs performing investment fiduciary services have a duty to confirm their compliance with either state or SEC regulations.2 Adopting employers can look up the registration status of their PPP using the SEC’s Investment Adviser search or by using FINRA’s Broker Check.
“We believe it is incumbent upon any PPP who delivers a comprehensive investment and plan administrator fiduciary solution to be an SEC registered investment adviser,” said Michael M. Salerno Founder and CEO of NPPG. He added, “In our view and that of our attorneys, it is requisite to the role we play and, frankly, makes sense from a fiduciary perspective to protect adopters and their participants.”
Salerno continued, “We recognize many PEP providers and employers may not have contemplated this requirement yet. Given the obvious motivation by adopting employers to reduce risk, we believe it is in every client’s best interest to avoid uncertainty around this requirement.”
Since 2021, the Setting Every Community Up for Retirement Enhancement (SECURE) Act has expanded access to retirement plans for companies of all sizes through the birth of PEPs. By their structure and operation, PEPs can achieve economies of scale that reduce administrative costs and mitigate fiduciary liabilities inherent with 401(k) retirement plans. As the named plan fiduciary, the Pooled Plan Provider (PPP) is responsible for plan governance which includes the selection of service providers and oversight of service delivery.
About NPPG Plan Professionals, LLC, an Affiliate of National Professional Planning Group (NPPG)
NPPG and its affiliate companies have been servicing clients since 1997 with their employee benefit and retirement plan needs. The NPPG family of companies services more than 7,000 plans, 250,000 participants, and more than $8 billion in plan assets nationwide including Puerto Rico. NPPG offers a full suite of services including, Pooled Plan Provider services, ERISA 3(16) administrative fiduciary services, actuarial services, retirement plan third-party administration for various plan structures (including Multiple Employer Plans (MEPs) and PEPs), institutional investment fiduciary services, and regulatory consulting. NPPG customizes solutions to meet the business and financial goals of its clients, which include members of the New York Stock Exchange and NASDAQ, internationally-known non-profit organizations, Fortune 500 companies, and government agencies, as well as small entrepreneurial businesses, associations, and Professional Employer Organizations (PEOs). For further information, visit www.nppg.com or call 1-(800) 340-5160.
Important Disclosures
NPPG and its affiliate companies are not law firms and do not provide legal services. Legal advice should be sought from a qualified professional. Opinions on investment adviser registration are those of NPPG and its principals as of the date of publication and are subject to change without notice. Statements regarding firm clients should not be construed as testimonials or endorsements of NPPG, its affiliates, or their respective personnel and should not be used as the sole determining factor when determining to hire, retain, or terminate an investment adviser and/or pooled plan provider.
1NPPG analysis of Form PR registration filings on US Department of Labor EFAST website. Accuracy of these counts is estimated but cannot be assured.
2Subject to state law, representatives of registered investment advisers are generally required to pass certain exams. This is a separate process from the actual act of registering as an investment advisory firm with the SEC, which alone does not imply a certain level of skill or training