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A Superior Collective Investment Trust Onboarding Experience.
A Superior Collective Investment Trust Onboarding Experience.
For small employers, offering a retirement plan has often meant doing more with less. PEPs change that equation.
Congress created pooled employer plans (PEPs) in the SECURE Act of 2019 to lower costs and simplify administration for small employers. The model is simple: one plan, many employers. A registered Pooled Plan Provider (PPP) serves as named fiduciary and plan administrator, and files a single Form 5500 in place of individual employer filings. Responsibility is shared, not handed off. Employers keep the duty to monitor the PPP.
PEP assets, participants, and adopting employers all grew sharply in 2025, and the market they’re reaching is small plans. Micro plans make up most 401(k) plans but hold a small share of the assets.1
Until recently, there were barriers for PEPs to access CITs. In May 2026, SEC staff said they would not object to CITs being offered within PEPs that cover self-employed individuals, which removed those barriers. That lets pooled scale and CIT pricing work together, and the savings are meaningful: the average actively managed mutual fund costs about three times as much as the average actively managed CIT.2
Employers weighing a PEP against their current plan may have questions about how it works and what it costs. Our primer, Big-Plan Economics for Small Plans: PEPs, CITs, and the Road Ahead, covers how PEPs work, their growth, and what clearer CIT access means for small employers.
Sources
1 PLANSPONSOR, 2026 Recordkeeping Survey: Industry Snapshot, Pooled Employer Plans (July 9, 2026); Cerulli Associates, The Cerulli Report: U.S. Defined Contribution Distribution 2026.
2 Morningstar, 2026 Retirement Plan Landscape Report (March 2026), Exhibit 13.
Great Gray Trust Company, LLC Collective Investment Funds (“Great Gray Funds”) are bank collective investment funds; they are not mutual funds. Great Gray Trust Company, LLC serves as the Trustee of the Great Gray Funds and maintains ultimate fiduciary authority over the management of, and investments made in, the Great Gray Funds. Great Gray Funds and their units are exempt from registration under the Investment Company Act of 1940 and the Securities Act of 1933, respectively.
Investments in the Great Gray Funds are not bank deposits or obligations of and are not insured or guaranteed by Great Gray Trust Company, LLC, any bank, the FDIC, the Federal Reserve, or any other governmental agency. The Great Gray Funds are commingled investment vehicles, and as such, the values of the underlying investments will rise and fall according to market activity; it is possible to lose money by investing in the Great Gray Funds.
Participation in Collective Investment Trust Funds is limited primarily to qualified retirement plans and certain state or local government plans and is not available to IRAs, health and welfare plans and, in certain cases, Keogh (H.R. 10) plans. Collective Investment Trust Funds may be suitable investments for plan fiduciaries seeking to construct a well-diversified retirement savings program. Investors should consider the investment objectives, risks, charges, and expenses of any pooled investment fund carefully before investing. The Additional Fund Information and Principal Risk Definitions (PRD) contains this and other information about a Collective Investment Trust Fund and is available at www.greatgray.com/cit-fund-info/principal-risk-definitions/ or ask for a free copy by contacting Great Gray Trust Company, LLC at (866) 427-6885.
Great Gray® and Great Gray Trust Company are service marks used in connection with various fiduciary and non-fiduciary services offered by Great Gray Trust Company, LLC.