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 |
---|---|---|
09/09/1986
|
Mr. Steven Bloom |
Whether the West Palm Beach Firefighters Benefit Fund is a "governmental plan" within the meaning of section 3(32) of title I of the Employee Retirement Income Security Act of 1974 (ERISA)and is, therefore, excluded from coverage under title I of ERISA pursuant to section 4(b)(1) thereof. |
08/29/1986
404(a) 405 406(b) |
Mr. John J. Cleary |
Whether the payment of incentive compensation to Batterymarch Financial Management by employee benefit plans will not result in a violation of section 406 of the Employee Retirement Income Security Act of 1974 (ERISA) or section 4975 of the Internal Revenue Code of 1954. |
08/29/1986
404(a) 405 406(b) |
Mr. Charles B. Schaffran |
Whether the payment of incentive compensation to BDN Advisers, Inc. by employee benefit plans will not result in a violation of section 406(b) of the Employee Retirement Income Security Act of 1974 (ERISA) or section 4975 of the Internal Revenue Code of 1954. |
08/22/1986
|
Mr. John P. Gallagher |
Whether the St. Agnes Medical Center Defined Benefit Pension Plan and Welfare Benefit Plans constitute church plans within the meaning of section 3(33) of title I of ERISA and, accordingly, whether they are excluded from coverage under title I of ERISA pursuant to section 4(b)(2) of ERISA. |
06/10/1986
|
Mr. James D. Kemper |
Whether employee benefit plans established and maintained for the employees of St. Francis Hospital, Beech Grove, Indiana, by the Eastern Province of the Congregation of the Sisters of St. Francis of Perpetual Adoration constitute church plans within the meaning of section 3(33) of title I of ERISA. |
04/28/1986
|
Mr. Paul S. Berger |
Whether certain fees paid to insurance brokers by insurance companies calculated on the aggregate value of certain classes of insurance policies placed or retained in one year must be reported on Schedule A of the Annual Return/Report Form 5500. |
04/10/1986
|
Mr. Mark D. Roth |
Whether the American Federation of Government Employees Union Leader Support Fund Plan is an employee welfare benefit plan within the meaning of section 3(1) of title I of ERISA. |
03/31/1986
|
Mr. Carl J. Bender, Jr. |
Whether the Waterman Medical Center Employee Benefit Plan is an employee welfare benefit plan covered by title I of the Employee Retirement Income Security Act of 1974 (ERISA). |
03/26/1986
|
Mr. Lynn A. Arnhold |
Whether the application of the annual reporting requirements under the Employee Retirement Income Security Act of 1974 (ERISA) require certain types of "fees" be reported in item 12 of the Form 5500. |
03/21/1986
|
H. Colin McBride, Esq. |
Whether an employee pension benefit plan which Sea-Land has established for its employees constitutes an eligible individual account plan under section 407(d)(3) of the Employee Retirement Income Security Act of 1974 (ERISA), and, therefore, is exempt from the limitations on the acquisition and holding of qualifying employer securities as provided in ERISA section 407(b)(1). |