To PEP Stakeholders:
As a leading pooled plan provider (PPP), NPPG Plan Professionals provides both administrative fiduciary and investment fiduciary services. To meet its fiduciary obligations, NPPG has successfully registered as an investment adviser with the Securities and Exchange Commission (SEC).
While dozens of entities have registered to become PPPs since the passage of the SECURE Act, NPPG is not aware of many other PPP’s that are SEC-registered investment advisers. This may have future implications for both service providers and participating employers.
NPPG, after conducting its own research and consulting with both trusted outside counsel and the SEC, understands registration with the SEC is required, and importantly, a prudent best practice to protect client interests. NPPG bases this conclusion in part on a recent No Action Letter it received from the SEC pertaining to this subject.
While other organizations may not rely directly on this advice or NPPG’s No Action Letter, we encourage others to pursue their own research on the matter. We further advocate others obtain their own final determination by requesting a No Action Letter from the Securities and Exchange Commission for their particular plan.
NPPG aims to raise awareness about this important issue by sharing this information with industry stakeholders.
If you have a question or challenge related to this topic, you may contact me at msalerno@nppg.com or 1-800-340-5160 extension 239.
Sincerely,
Michael M. Salerno
Founder & CEO