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.

2002
Date Recipient Description of Request
Information Letter
2002-11-04

Mr. Sherwin Kaplan
Thelen Reid & Priest LLP
Attorneys At Law
Market Square, Suite 800
701 Pennsylvania Avenue, NW
Washington, DC 20004-2608

Whether the International Union for the Natural Health, Complementary & Alternative Medicine Professions Health and Welfare Fund is established or maintained under or pursuant to one or more collective bargaining agreements for purposes of section 3(40)(A)(i) of ERISA.

Information Letter
2002-08-23

The Honorable John W. Oxendine
Insurance and Safety Fire Commissioner
Georgia Department of Insurance
Two Martin Luther King, Jr., Drive
West Tower, Seventh Floor
Atlanta, Georgia 30334

Whether and to what extent the State of Georgia may regulate the International Union of Industrial and Independent Workers Benefit Fund under section 514(b)(6)(A) of title I of ERISA.

Information Letter
2002-05-17

Mr. Richard M. Steinberg, Chair
Employee Benefit Plans Expert Panel
Department of Labor Liaison Task Force
American Institute of Certified Public Accountants
1455 Pennsylvania Avenue, N.W.
Washington, D.C. 20004-1081

Application of the certification requirements of 29 CFR 2520.103-5, for purposes of the limited scope audit provisions of ERISA Sec. 103(a)(3)(C) and 29 CFR 2520.103-8.

2001
Date Recipient Description of Request
Information Letter
2001-02-15

Theodore R. Groom
Groom Law Group
1701 Pennsylvania Ave., NW
Washington, D.C. 20006-5893

Guidance regarding the alternatives available under the trust requirement of Title I of ERISA with respect to receipt by policyholders of demutualization proceeds belonging to an ERISA covered plan in connection with The Prudential Insurance Company of America’s proposed plan of demutualization.

1998
Date Recipient Description of Request
Information Letter
1998-09-23

Carol I. Buckmann
Sullivan & Cromwell
125 Broad Street
New York, New York 10004-2498

Whether initial capital contributions from employee benefit plan investors transferred for the purpose of venture capital investments will be treated as plan assets at any time after transfer on the initial valuation date within the meaning of DOL Regulation 29 C.F.R. § 2510.3-101.