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A new era for 403(b) plans: CITs and PEPs unlock efficiency and enhance participant outcomes

By Holly Tardif | November 14, 2025

A new era for 403(b) plans: CITs and PEPs bring cost savings and efficiency. Time for plan sponsors to unlock this opportunity!

A new era for 403(b) plans: CITs and PEPs unlock efficiency and seek to enhance participant outcomes

The new legislation allowing 403(b) plans to offer Collective Investment Trusts (CITs) ushers in a new era of opportunity for 403(b) plan sponsors and participants alike. This long-awaited change brings 403(b) plans in line with their 401(k) counterparts, enabling plan sponsors to leverage more cost-effective investment structures. But the impact of this legislative shift extends beyond investment vehicles. It opens the door for plan sponsors to adopt more efficient plan delivery models, such as Pooled Employer Plans (PEPs), to further enhance the value they provide to participants.

CITs: Paving the way for greater efficiency

We believe CITs offer a significant advantage over traditional mutual funds by providing institutional pricing, streamlined fee structures and reduced regulatory overhead. With these benefits, 403(b) plan sponsors can achieve meaningful cost savings while maintaining a diversified, well-governed investment menu. However, the potential benefits of this change go beyond cost efficiencies. CITs provide plan sponsors with a wider opportunity set of available investments to improve participant outcomes through institutional-quality investments that seek superior long-term performance and lower volatility.

PEPs: Delivering administrative relief and participant benefits

With CITs now available to 403(b) plans, plan sponsors can use the same institutional knowledge and oversight that 401(k) plans have used through PEPs. Historically, 403(b) plan sponsors had significant administrative burdens, regulatory complexities and fiduciary responsibilities that strained internal resources. A PEP simplifies these challenges by consolidating plan management under a centralized governance structure. This allows multiple employers to pool their resources and gain access to a more streamlined and cost-effective solution.

For participants, this shift is not just about cost savings. It is about improving the retirement journey. By moving to a PEP, participants gain access to:

  • Higher quality investment options: With CITs included in a PEP structure, participants can benefit from lower-cost, institutionally priced funds that may enhance long-term retirement outcomes.
  • Enhanced participant experience: Consolidated plan administration results in more consistent and efficient service delivery, reducing errors, delays and confusion. PEPs streamline recordkeeping, communications, and support under a unified structure. They eliminate the fragmented processes that often lead to missteps and frustration in traditional 403(b) plans.
  • Stronger fiduciary oversight: PEP fiduciaries are dedicated experts who provide consistent governance and oversight, ensuring that the plan operates in the best interests of all participants.

Redefining the future of 403(b) plans

With the legislative hurdle cleared, 403(b) plan sponsors are now empowered to rethink how they deliver retirement benefits. The combination of CITs and PEPs offers a compelling opportunity to improve both operational efficiency and participant outcomes. As sponsors evaluate their next steps, one question stands out: Will they seize this opportunity to modernize their plans and better serve their participants, or remain tethered to outdated structures that limit growth and potential? For forward-thinking plan sponsors, we believe the answer is clear. Those who embrace these advancements early may position themselves and their participants for a more secure and prosperous future.

Disclaimer

This document provides information on LifeSight Pooled Employer Plan (PEP) services that are being offered to you by WTW. Willis Towers Watson US LLC and Towers Watson Investment Services, Inc. or their affiliates are not acting in the capacity of providing “Investment Advice” within the meaning of 29 C.F.R. § 2510.3-21. It is your decision whether to engage WTW to provide any services or to invest in any investment available through WTW’s LifeSight PEP offering.

This document was prepared for general information purposes only and does not take into consideration individual circumstances. The information contained herein should not be considered a substitute for specific professional advice. In particular, its contents are not intended by Willis Towers Watson US LLC and Towers Watson Investment Services, Inc., and their parent, affiliates, and their respective directors, officers and employees (WTW) to be construed as the provision of investment, legal, accounting, tax or other professional advice or recommendations of any kind, or to form the basis of any decision to do or to refrain from doing anything. The information included in this presentation is not based on the particular investment situation or requirements of any specific trust, plan, fiduciary, plan participant or beneficiary, endowment, or any other fund; any examples or illustrations used in this presentation are hypothetical. As such, this document should not be relied upon for investment or other financial decisions and no such decisions should be taken on the basis of its contents without seeking specific advice. WTW does not intend for anything in this document to constitute “investment advice” within the meaning of 29 C.F.R. § 2510.3-21 to any employee benefit plan subject to the Employee Retirement Income Security Act and/or section 4975 of the Internal Revenue Code.

This document is based on information available to WTW at the date of issue, and takes no account of subsequent developments. In addition, past performance is not indicative of future results. In producing this document WTW has relied upon the accuracy and completeness of certain data and information obtained from third parties. This document may not be reproduced or distributed to any other party, whether in whole or in part, without WTW’s prior written permission, except as may be required by law. Views expressed by other WTW consultants or affiliates may differ from the information presented herein. Actual recommendations, investments or investment decisions made by WTW, whether for its own account or on behalf of others, may differ from those expressed herein.

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Director, Retirement

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