September 30, 2020

The Honorable Jeanne Klinefelter Wilson
Acting Assistant Secretary
Employee Benefits Security Administration
Department of Labor
200 Constitution Ave., NW
Washington, DC 20210

Re: Registration Requirements for Pooled Plan Providers

Dear Secretary Wilson:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to respond to the Department of Labor’s (the “Department”) proposal with regard to registration of pooled employer plans (PEPs). We strongly support the Department moving this rulemaking forward in a timely manner.

We worked closely with Members of Congress in support of the Setting Every Community Up for Retirement Enhancement Act (the “SECURE Act”), which provided for the creation and establishment of PEPs. Included in that law are new Sections 3(44) of ERISA and 413(e)(3) of the Internal Revenue Code of 1986, as amended, that require Pooled Plan Providers (PPPs) to register with the Department and the Treasury Department, respectively, before beginning operations as a PPP.

The Department’s proposal of a new Form PR (Pooled Provider Registration) is an important first step in implementing the SECURE Act’s PEP provisions. Our comments are intended to improve and streamline Form PR and to enhance efficiency in the PPP registration process, which we believe is important to encouraging the adoption and growth of the PEP marketplace and increasing retirement savings in America.