Advisory Opinions
Requests for interpretations and other rulings under Title 1 of ERISA are handled by the Office of Regulations and Interpretations under the provisions established by ERISA Procedure 76-1. The office answers inquiries from individuals and organizations in the form of advisory opinions, which apply the law to a specific set of facts, or information letters, which merely call attention to well established principles or interpretations.
AO/ Date/ Reference | Recipient | Description of Request |
---|---|---|
06/16/1995
3(33) 4(b)(2) |
Mr. James F. Podheiser |
Whether benefit plans for the employees of St. Joseph's University in Philadelphia, Pennsylvania, an institution of the Jesuit Fathers and Brothers, are “church plans” within the meaning of ERISA section 3(33). |
06/16/1995
3(33) 4(b)(2) |
Mr. John J. Hunter |
Whether benefit arrangements for employees of the Archmere Academy, Inc., an institution of the Canons Regular of Premontre a/k/a the Norbertine Fathers, are “church plans” within the meaning of ERISA section 3(33). |
06/16/1995
3(33) 4(b)(2) |
Ms. Anne E. Moran |
Whether the health benefit plans of eight institutions of the Sisters of St. Francis of the Perpetual Adoration are “church plans” within the meaning of ERISA section 3(33) and are thus excluded from ERISA Title I requirements by section 4(b)(2). |
03/06/1995
3(33) 4(b)(2) |
Mr. Gair Petrie |
Whether the Providence Services Pension Plan is a “church plan” or plans within the meaning of ERISA section 3(33) where Providence Services is an institution of St. Ignatius Province of the Sisters of Providence. |
05/18/1995
3(40) 514(b)(6) |
Mr. Tom Portier |
Whether Mid-Continent Medical Benefits Trust, administered by Profession Administration Group, is a “multiple employer welfare arrangement” within the meaning of ERISA section 3(40)(A). |
05/18/1995
3(1) |
Mr. Paul A. Green |
Whether the United Mine Workers of America - Bituminous Coal Operators' Association, Inc. Labor Management Positive Change Process Fund is an “employee welfare benefit plan” within the meaning of ERISA section 3(1). |
05/03/1995
401(b) |
Mr. Robert Stillman |
Concerning the application of the venture capital operating company exception of the "plan assets" regulation (29 C.F.R. 2510.3-101) to Small Business Investment Companies. |
04/03/1995
3(1) 3(4) 3(40) |
Ms. Térese M. Connerton |
Whether certain proposed changes to the American Federation of Government Employees Dental Trust Fund would cause the Fund to be considered an "employee welfare benefit plan" within the meaning of ERISA section 3(1), but not a "multiple employer welfare arrangement", as defined in ERISA section 3(40). |
03/06/1995
3(33) 4(b)(2) |
Ms. Melissa B. Rasman |
Whether the employee benefit arrangements of Jeanes Hospital, a medical care institution of the Religious Society of Friends, are “church plans” within the meaning of ERISA section 3(33) of and thus excluded from Title I coverage by ERISA section 4(b)(2). |
02/13/1995
3(1) |
Mr. Kenneth R. Hoffman |
Whether The Pennsylvania Division, Horsemen's Benevolent & Protective Association Health Benefit Plan is an “employee welfare benefit plan” within the meaning of ERISA section 3(1). |