This document is about an advisory opinion from the U.S. Department of Labor regarding whether the Dunkin' Donuts Franchisee & Distribution Center Health Plan is a "multiple employer welfare arrangement" (MEWA) under ERISA and whether it would be considered "fully insured" within the meaning of ERISA. The Department concludes that the plan would be a MEWA, but cannot determine if it would be fully insured without seeing the actual insurance contract.