As a business grows, milestones are usually a cause for celebration. Hiring your 50th employee, hitting your first $10 million in revenue, or expanding to a second location are all signs of a healthy, thriving company. However, there is one milestone in the world of retirement planning that most business owners dread: hitting the 100-participant mark in their 401(k) plan.
Why the dread? Because in the eyes of the Department of Labor (DOL) and the IRS, hitting that number typically moves your plan from "small" to "large," triggering a mandatory annual independent audit. For many businesses, this realization comes with a significant bill: often ranging from $10,000 to over $20,000: and a massive administrative headache.
But what if you could bypass that cost entirely? At Castle Rock PEP, we believe that your growth shouldn't be penalized. By leveraging a pooled employer plan (PEP), businesses can eliminate the need for individual audits, reduce their fiduciary liability, and focus on what they do best: running their business.
If you are currently managing a traditional single-employer 401(k) plan, you are likely familiar with the annual Form 5500 filing. When your plan reaches "large plan" status: generally when you have 100 or more eligible participants at the beginning of the plan year: the DOL requires that an independent Qualified Public Accountant (IQPA) audit your plan's financial statements.
This audit isn't just a quick check of the math. It is a deep dive into your plan's operations and the audit process (learn more on our Regulators and Audits page), testing everything from:
For a mid-sized business, the cost is two-fold. First, there is the financial cost. Paying a CPA firm to conduct this audit year after year is a significant drain on company resources. Second, there is the internal resource cost. Your HR and finance teams must spend dozens of hours gathering documents, answering auditor questions, and tracking down historical data.
The SECURE Act of 2019 changed the landscape of retirement planning forever by introducing the Pooled Employer Plan. Before this, "Multiple Employer Plans" (MEPs) existed, but they required a "common bond" between companies (like being in the same industry). PEPs removed that barrier, allowing unrelated businesses to join a single, professionally managed plan.
The most significant advantage for companies approaching or exceeding the 100-participant threshold is how audits are handled. In a low cost 401(k) structure like a PEP, the plan itself is treated as a single entity.
Instead of 50 different companies each paying for 50 different audits, Castle Rock PEP handles one single audit for the entire pool. The cost of that audit is shared across all participating employers, making the individual cost to your business negligible or even zero, depending on your plan structure.
By making the switch, your company can effectively "outsource" the audit requirement. You no longer have to hire the auditor, you no longer have to host them in your office, and you no longer have to cut that five-figure check every year.
Cost savings are the headline, but the reduction in "mental load" for business owners and HR managers is the real hero of the story. Managing a 401(k) is a full-time responsibility that most businesses try to squeeze into an already packed schedule.
When you join a pooled employer plan, you are handing off the heavy lifting to a Pooled Plan Provider (PPP). At Castle Rock PEP, we take on the role of the lead fiduciary and plan administrator. This means we are responsible for:
Our outsourced administration services ensure that you aren't bogged down by the minutiae of eligibility tracking or contribution testing. And if you're looking for practical resources to make oversight easier, tools like our fee disclosure review worksheets can be found in our Fiduciary Tool Belt. We've built a system designed to scale with you, whether you have 10 employees or 500.
In a traditional 401(k) environment, the business owner often serves as the "Named Fiduciary." This means if a mistake is made: even an accidental one: the owner is personally liable for any losses or penalties.
By moving to a PEP, you shift that burden. Castle Rock PEP acts as the 3(16) Administrative Fiduciary and the 3(38) Investment Manager. We are the ones "on the hook" for ensuring the plan is run correctly and the investments are prudent. This level of fiduciary protection is something that many small to mid-sized businesses simply cannot afford on their own, but it comes standard in our pooled model. We also offer specialized fiduciary training to help you and your committee stay ahead of the curve.
While PEPs are a fantastic fit for almost any business looking for a low cost 401(k) solution, they are particularly advantageous for:
You can check out our pricing page to see how our transparent fee structure compares to what you are currently paying for a stand-alone plan and its associated audit costs.
In states like Colorado, the regulatory environment is getting tighter. With the Colorado compliance trap and new data-sharing requirements, businesses are under more pressure than ever to provide compliant retirement solutions.
A PEP doesn't just save you money on audits; it ensures you stay ahead of these mandates without having to become a compliance expert yourself. We handle the paperwork, the filings, and the state-level reporting, so you can focus on your people and your profits.
The "old way" of doing things: where every small and mid-sized business struggled with their own complex, expensive, and risky retirement plan: is fading. The pooled employer plan is the modern solution that brings "big company" benefits and efficiencies to businesses of all sizes.
By eliminating the 401(k) audit cost, reducing your administrative workload, and providing professional fiduciary oversight, Castle Rock PEP allows you to offer a world-class benefit to your employees without the world-class headache.
If you're approaching the 100-participant threshold (or you're already there), a little preparation can make the audit process feel a lot more manageable—whether you stay with a stand-alone plan or decide to switch to a PEP.
On our Regulators and Audits page, you'll find two helpful resources designed to give you practical, plain-English guidance:
If you want, bookmark those resources and share them with your HR and finance teams—getting aligned early is often the easiest win.
Ready to see how much you could save by ditching your standalone audit? It's time for a PEP Talk. Let us show you how we can simplify your retirement plan and protect your bottom line.
Take the next step:
Simplifying retirement for all. One plan. Every business.
This content was prepared with the assistance of artificial intelligence tools and reviewed by Castle Rock Investment Company for accuracy and completeness.