DOL and IRS Expand Access to Multiple Employer Plans and Propose to Eliminate the ‘One Bad Apple’ Rule

By and on December 17, 2019

Recently, the Department of Labor (DOL) published final rules clarifying the circumstances under which “bona fide” groups or associations of employers and professional employer organizations (PEOs) may be permitted to sponsor single defined contribution multiple employer plans (MEPs). Concurrently, the Internal Revenue Service (IRS) published proposed rules detailing an exception to the “one bad apple” rule for defined contribution MEPs, which rule provides that the failure of one employer to meet established qualification requirements results in the disqualification of the MEP for all participating employers.

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Joshua N. LernerJoshua N. Lerner
Joshua N. Lerner focuses his practice on a variety of executive compensation, employee benefits, corporate governance and securities matters. He has experience advising public and private companies and individual senior executives on executive compensation and benefits matters in a range of corporate transactions and in a regular advisory role. Joshua also counsels clients on ongoing public company matters, including their Securities Exchange Act of 1934 reports and corporate governance and disclosure compliance, and has experience advising clients on a wide range of equity-based incentive plans, cash-based incentive and employment, change-in-control, retention and separation agreements.


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