This document is about a Department of Labor advisory opinion on whether the Public Employees Defined Contribution Plan administered by the Public Employees Retirement Association of Minnesota is a governmental plan excluded from ERISA Title I coverage under ERISA Section 3(32). The opinion concludes that the plan is a governmental plan and is excluded from ERISA Title I coverage, but notes that if the plan is extended to cover more than a de minimis number of private sector employees, it would be subject to ERISA.