Department of Labor Pension and Welfare Benefits Administration Advisory Opinion 95-24A

This document is about a Department of Labor advisory opinion on whether a plan administrator may refund withdrawal liability overpayments without violating ERISA Section 403(c)(1)'s anti-inurement rule. The opinion concludes that the plan administrator may refund mistaken withdrawal liability payments under ERISA Section 403(c)(2)(A)(ii) if the administrator determines the payments were made by mistake of fact or law.