Information Letters

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 information letters, which call attention to well established principles or interpretations.

**2006**
Date	Recipient	Description of Request
Information Letter 2006-05-08	The Honorable George J. Chanos Attorney General Nevada Department of Justice 555 East Washington Avenue Las Vegas, Nevada 89101-1088	Whether an arrangement providing benefits to employees of the clients of a professional employer organization is a multiple employer welfare arrangement under ERISA section 3(40).
Information Letter 2006-03-01	The Honorable Mike Kreidler Insurance Commissioner Washington Office of Insurance Commissioner P.O. Box 40255 Olympia, WA 98504-0255	Whether a professional employer organization (PEO) and its client companies would be deemed a single employer for purposes of ERISA section 3(40) by reason of the PEO obtaining options to purchase an 80% interest in each client company.

**2005**
Date	Recipient	Description of Request
Information Letter 2005-02-23	Mr. William Lindsay Local 25 IBEW 370 Vanderbilt Motor Parkway P.O. Box 18033 Hauppauge, NY 11788-8833	Whether a plan fiduciary engages in a breach by accepting, and then returning, contributions to his political campaign from current and prospective service providers to the plan, and recusing himself from decisions relating to those service providers.

**2004**
Date	Recipient	Description of Request
Information Letter 2004-05-24	Mr. Nicholas W. Ferrigno, Jr. Greenebaum Doll & McDonald PLLC Post Office Box 2673 Covington, KY 41012-2673	Whether an "affiliated service group" within the meaning of section 414(m) of the Internal Revenue Code (Code) is a "single employer" for purposes of section 3(40) of ERISA.
Information Letter 2004-01-06	Jon W. Breyfogle, Esq. Groom Law Group, Chartered 1701 Pennsylvania Avenue, NW Washington, D.C. 20006-5893	Guidance as to whether certain group annuity contracts may satisfy the definition of a "guaranteed benefit policy" contained in section 401(b)(2) of ERISA.