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PEPs in Practice: Small Plan Advisors Are Least Familiar

Author

Deb Dupont
Assistant Vice President Workplace Benefits Research, Institutional Retirement
LIMRA and LOMA
ddupont@limra.com

June 2026

PEPs are not the norm for most defined contribution plan advisors, even those who specialize in workplace retirement. Given expanding state mandates for coverage, federal efforts to increase coverage and participation, a litigious environment around plan design, fees and performance issues — and the fact that PEPs are of interest even to sponsors of larger plans — there’s tremendous potential for growth in this market.

Since 2021, a new construct has been available to employers who want to sponsor a workplace retirement savings program but may be reluctant to take on the role of an active plan sponsor — the pooled employer plan (PEP). Introduced by the SECURE Act at the end of 2019, PEPs are intended to attract smaller employers that may not currently offer a plan by providing a convenient, lower-effort, and lower-liability option than a traditional, single-employer plan for offering a retirement investment benefit to their employees.

Joining a PEP allows an employer to “transfer” the role — and most responsibilities — of a plan sponsor to a pooled plan provider (PPP). The PPP is a newly created entity that assumes responsibility for vendor selection and management, as well as many plan design and administrative responsibilities.

As of March 2026, nearly 200 PEPs had been registered with the Department of Labor (DOL), according to publicly available Form PR filings maintained by the DOL’s Employee Benefits Security Administration. Estimates of PEP assets as of year-end 2024 are in the $16 to $17 billion range, with PLANSPONSOR estimating that nearly half are in plans with $200 million or more in assets (see “PEPs by the Numbers,” March 3, 2026, https://www.planadviser.com/peps-by-the-numbers), perhaps not the best testament to PEPs increasing coverage among employers of smaller companies — the ostensible original intent of the SECURE provision that created the PEP construct and the role of a PPP.

Our research with advisors illustrates this dynamic. We find that advisors who specialize in defined contribution (DC) plans — who also tend to work with more, but larger plans — report greater familiarity and comfort with PEPs than do their counterparts with less DC practice exposure, who tend to advise smaller employers and plans. In late 2025, we commissioned NMG Consulting to survey 160 advisors who sell and/or service DC plans as part of our annual DC Advisor Views series of research, an effort that solicits advisor views of timely and topical industry issues.

About five years into this market, familiarity with PEPs is (still) low, most especially among advisors for whom supporting retirement plans is only a small part of their practice(s). Among “occasional” DC advisors, for whom plans represent less than 20% of practice income, more than half report low (if any) familiarity with PEPs. At the other end of the advisor spectrum, among specialist advisors (deriving 50% or more of practice income from DC activity), 66% report familiarity with PEPs.

Only 9% of DC advisors overall report that they are “very” familiar with PEPs. Combining familiarity with PEPs and the size of advisors’ average DC plan highlights the disconnect referenced above:

  • Among occasional advisors, who may sell DC plans but do not make them a main practice focus, just 3% are very familiar with PEPs, while 83% report that their average DC client plan is less than $5 million (including 39% under $1 million).
  • Specialists, who focus much more exclusively on DC, report that just 30% of their plans under advisement are $5 million or less, yet 22% say they are “very” familiar with PEPs.

Similarly, 22% of specialist advisors have clients who are currently in a PEP, compared to just 5% of occasional advisors (Figure 1). Another 28% of specialists say that they are in exploratory PEP discussions with clients, compared to just 13% of occasional advisors. Two-thirds (65%) of occasional advisors, however, respond “no, not yet” when asked about the potential for PEP consideration for their clients. Specialist and occasional advisors are similar in the extent to which they are not having PEP discussions and do not anticipate doing so — 22% and 18%, respectively.

Figure 1. Have You Advised Clients Who Are Considering or Already Participating in a PEP?

Filter the data in this chart by clicking on a color bar in the chart legend.

All advisors, regardless of DC focus, are open to support, information, education and tools to better inform their clients and support their own PEP marketing efforts. Occasional advisors are slightly more open to training and education for themselves, while specialists are more likely to be looking for more specialized support, such as fee benchmarking and legal and regulatory guidance.

Figure 2. How Important Would the Following Tools be to Make You Feel More Confident About Advising Clients on PEPs?

Important and Very Important

Filter the data in this chart by clicking on a color bar in the chart legend.

Clearly, education and tools related to PEPs are needed for advisors — especially occasional advisors — to further leverage the potential of PEPs. Manufacturers and providers of PEPs and PEP services have their work cut out for them in resolving the potential disconnect between the original intent of the PEP design — creating a simple, lower-hassle, lower-responsibility option for smaller employers — and how those plans are perceived by advisors who most frequently sell DC plans in the smaller market.

Educating these advisors about PEPs, both in theory and practice, will be critical for providers seeking to expand coverage among smaller employers and plans, including new or startup plans. Offering clearly defined support services and practical tools will also be key components of a successful PEP strategy.

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