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Fiduciary Investment Selection for Pooled Plans
Ongoing monitoring and investment lineup management for CPEPs — supporting compliant, diversified options for participating employers and their teams.
Retirement Plan Advisory
Explore our fiduciary advisory services for employer-sponsored retirement plans. Select a service below to preview our approach — then visit the full page for a deeper look.
Institutional-Quality Retirement Plans for Small and Mid-Size Employers
A Pooled Employer Plan (PEP) is a multi-employer 401(k) plan created under the SECURE Act that allows unrelated businesses to join a single, professionally managed retirement plan. Instead of each employer bearing the full cost and fiduciary burden of running their own plan, a PEP pools multiple companies under one plan structure — with shared administration, investment management, and compliance oversight.
The plan is managed by a Pooled Plan Provider (PPP) who takes on the fiduciary responsibilities that would otherwise fall on each individual employer. Participating employers simply adopt the plan, contribute through payroll, and their employees participate like any other 401(k) — but with access to institutional-quality investments, lower fees through pooled buying power, and a level of administrative support that most small businesses could never afford on their own.
PEPs were designed to solve a real problem: the majority of small businesses in America don't offer a retirement plan because it's too expensive, too complex, and too risky from a fiduciary standpoint. PEPs eliminate all three barriers.
The Benefits of a Pooled Approach
PEPs were created because the old model was broken — small employers couldn't afford or manage their own retirement plans. A pooled structure solves the cost, complexity, and liability problems simultaneously.
Lower Costs Through Scale
Pooling dozens or hundreds of employers into one plan creates institutional buying power — lower recordkeeping fees, access to institutional share classes, and administrative cost sharing that no single small employer could achieve alone.
Fiduciary Liability Transfer
The Pooled Plan Provider assumes the named fiduciary role — taking on the investment selection, monitoring, and compliance responsibilities that would otherwise rest on each employer. Participating employers retain only a limited set of duties like timely payroll remittance.
Turnkey Administration
No plan document to draft, no Form 5500 to file, no nondiscrimination testing to manage. The PPP and TPA handle everything — the employer's only job is to set up payroll deductions and make timely contributions.
Talent Recruitment & Retention
Small businesses that couldn't previously afford a 401(k) can now offer one — leveling the playing field with larger employers in the competition for talent. Employees get a real retirement plan, not a referral to open their own IRA.
SECURE Act Tax Credits
Employers joining a PEP for the first time may be eligible for SECURE Act 2.0 startup tax credits — up to $5,000 per year for three years, plus an additional credit for employer contributions. The PEP itself often qualifies the employer for these credits automatically.
Professional Investment Oversight
A designated investment fiduciary — like BRIM in a 3(38) capacity — selects and monitors the investment menu for the entire pool. Participants get access to a professionally managed, diversified lineup that's reviewed quarterly, not a static list of retail funds.
The Roles Inside a Pooled Employer Plan
A PEP has clearly defined roles — each party handles a specific set of responsibilities, so no single employer bears the full weight of running a retirement plan.
Pooled Plan Provider (PPP)
The PPP is the named fiduciary and plan administrator. They're responsible for the plan document, ERISA compliance, investment governance, and ensuring every participating employer meets their obligations. The PPP registers with the DOL and files Form PR annually.
Investment Fiduciary (3(38))
The investment advisor — designated by the PPP — takes on discretionary authority over the plan's investment lineup. They select funds, monitor performance, replace underperformers, and maintain the Investment Policy Statement. This is where BRIM would serve.
Recordkeeper & TPA
The recordkeeper maintains participant accounts, processes transactions, and provides the participant portal. The TPA handles nondiscrimination testing, Form 5500 filings, and plan compliance. TRPC's open-architecture platform and administration capabilities make them a natural fit for this role.
Participating Employers
Each employer signs a participation agreement, sets up payroll deductions, and remits contributions on time. That's largely it. They don't file Form 5500, don't run nondiscrimination testing, and don't bear investment fiduciary liability — those responsibilities belong to the PPP.
BRIM Is Building a Pooled Employer Plan Solution
We're developing a Pooled Employer Plan offering designed to bring institutional-quality retirement benefits to small and mid-size businesses — with BRIM as investment fiduciary and TRPC providing administration and recordkeeping. If you're an employer interested in offering a 401(k) without the cost and complexity of running your own plan, or an advisor looking to place clients into a professionally managed PEP, we'd love to hear from you.
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