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
1976-103 09/13/1976	Department of Labor	Whether Mr. (x), who negotiated a training trust fund with two local unions on behalf of a city council, would be considered a party in interest under ERISA if he was chosen to conduct training with the trust on a contract basis and if so, whether that would be legal.
1976-102 02/19/1976 406(a)	Anonymous	Whether the purchase of land by a plan from the estate of the deceased sole shareholder of a participating employer constitutes a prohibited transaction under section 406(a) of ERISA.
1976-101 11/01/1976 3(4) 3(5)	Anonymous	Whether a pension plan maintained by a labor organization is subject to the requirements of Title I of ERISA.
1976-100 11/15/1976 401 3(2) 403	Anonymous	Whether a management profit sharing plan is an employee benefit pension plan under ERISA.
1976-09 02/10/1976 3(2)	Anonymous	Whether renewal commissions on from the sale of life insurance policies to employees constitute a deferred income and, in turn, whether such deferred income constitutes a pension benefit plan under ERISA.
1976-08 01/26/1976 3(2) 3(5)	Anonymous	Whether Title I of ERISA, Parts 1 and 4, apply to IRAs offered to an association for the executives and employees of its employer members if the association plans no continuing involvement after recommending them to its members, for which it will receive a service fee and be indemnified against loss arising from the presentation.
1976-07 01/26/1976 3(2)	Anonymous	Inquiry regarding the applicability of the reporting and disclosure requirements of ERISA to the Incentive Savings Plan of The Savings Bank. Specifically concerns whether the Plan, which allows liberal withdrawal provisions any time a participant chooses, qualifies as an "employee pension benefit plan" under ERISA.
1976-06 04/30/1976 3(1)	Anonymous	Whether an insured arrangement providing life, accident, and health benefits maintained by an organization is subject to the provisions of Title I of the ERISA.
1976-05 04/30/1976 3(1)	Anonymous	Whether a "Group Medical Coverage Agreement" constitutes a welfare benefit plan under ERISA, specifically whether the group health coverage provider is an “insurance or similar organization which is qualified to do business in any State.”
1976-04 04/22/1976 3(1) 3(4)	Anonymous	Whether a scholarship fund maintained by all county labor organizations affiliated with the AFL-CIO is covered under ERISA.