Advisory Opinions

Whether a self-funded health benefit program sponsored by Advantage Corporate Services Inc is a multiple employer welfare arrangement (MEWA), within the meaning of ERISA section 3(40) and, if so, whether the application of the Texas insurance laws would be inconsistent with the provisions of ERISA.

Whether the Food Employers Labor Relations Association and Retail Store Employees Union Severance Plan would be a severance pay plan described in Department of Labor regulation section 29 C.F.R. 2510.3-2(b) if certain described acts occur.

Whether a stop-loss insurance policy purchase by the employer sponsoring a welfare benefit plan that provides benefits exclusively out of the employer general assets would be assets of the plan under ERISA.

Whether the Emergency Relief Fund of the Southern Labor Union is an unfunded dues financed welfare plan maintained by an employee organization within the meaning of Department of Labor regulation section 29 C.F.R. 2520.104-26 and therefore exempt from filing certain reports with the Department or disclosing certain information to participants.

Whether several employee benefit plans of the St. Mary's Hospital, Inc. constitute church plans within the meaning of section 3(33) of title I of ERISA and, accordingly, whether the plans are excluded from the requirements of title I of ERISA by section 4(b)(2).

Whether the National Employees and Operators Association Trust is saved from such authority under the general preemption provision of section 514(a) of title I of ERISA because it is a MEWA or is subject to the applicable regulatory authority of the state of Tennessee's insurance law.

Whether the Construction Industry Service Corporation Trust (the CISCO Trust) is an employee welfare benefit plan within the meaning of section 3(1) of title I of ERISA.

Whether the Florida Association of Blood Banks Group Insurance Trust (the Trust), created as a Voluntary Employee Benefit Association Trust, is a MEWA within the meaning of ERISA section 3(40) and subject to state regulation to the extent provided in section 514(b)(6)(A).

Whether Diversified Industrial Group (DIG), a self- insured or partially self- insured trust that provides health and other benefits to members of the International Union of Petroleum and Industrial Workers, is an "employee welfare benefit plan" within the meaning of ERISA section 3(1). Whether state regulation is preempted under ERISA section 514(a).

Whether the Associated General Contractors of America, Inc. (AGC) Health Benefit Trust (the Trust) is a multiple employer welfare arrangement (MEWA) within the meaning of section 3(40) of title I of ERISA and therefore subject to the applicable regulatory authority of the State of Oregon.