Department of Labor Pension and Welfare Benefits Administration Advisory Opinion 95-23A

This document is about a Department of Labor advisory opinion on whether the M.G.S.I., Inc. Contingent Equity Ownership Program constitutes an employee pension benefit plan under ERISA Section 3(2). The opinion concludes that the program does not appear to be an employee pension benefit plan under ERISA based on its express terms, but notes that it could be considered a pension plan based on the surrounding circumstances.