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.

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**1976**
AO/ Date/ Reference	Recipient	Description of Request
1976-122 12/10/1976 3(32)	Anonymous	Whether a city's noncontributory group hospital and surgical plan for its employees is a governmental plan and therefore exempt from coverage under ERISA.
1976-121 12/09/1976	Anonymous	Whether an employer's three employee welfare plans, each covering fewer than 100 participants, qualify for exemptions from certain reporting and disclosure requirements under ERISA as per §2520.104-20 of the regulations issued August 15, 1975.
1976-120 12/08/1976 3(14)	Anonymous	Whether a credit union and its proposed transaction involving the depository functions for multiple employee benefit plans are in compliance with the provisions of the Employee Retirement Income Security Act of 1974 (ERISA), including whether the credit union is a party in interest and whether exemptions apply to the transfer of fund assets to the credit union.
1976-12 02/09/1976 3(2) 3(3)	Anonymous	Whether a non-qualified employee stock purchase plan offered by a bank to various companies is a pension or welfare plan under ERISA.
1976-119 11/19/1976 3(1) 3(2)	Anonymous	Whether the supplemental payments to pensioners made by the employer constitute an employee pension benefit plan under the Employee Retirement Income Security Act of 1974 (ERISA) and are subject to Title I of ERISA.
1976-118 11/15/1976 3(2) 401(a)(1) 403(a)	Anonymous	Whether a profit sharing plan adopted by 14 corporations is considered an employee pension benefit plan under ERISA.
1976-117 10/30/1976 3(32)	Anonymous	Whether a town’s pension plan for its employees is exempt from coverage under Title I of the Employee Retirement Income Security Act (ERISA), as a "governmental plan" under section 3(32) of ERISA.
1976-116 10/30/1976 3(1)	Anonymous	Whether an organization’s insured benefit program, which provides accident, medical, and life protection to a small group of employees, is subject to the reporting and disclosure requirements under Title I of ERISA.
1976-115 10/30/1976 3(1)	Anonymous	Whether hospitalization plan is required to file Form EBS-1 under ERSIA.
1976-114 10/30/1976 3(2)	Anonymous	Whether a stock purchase plan that allows employees to purchase stock but does not provide retirement income or result in a deferral of income qualifies as an "employee pension benefit plan" under ERISA.