Advisory Opinions

Whether Consumer Association for Security and Health Medical Benefit Trust (the Trust) is a multiple employer welfare arrangement (MEWA) within the meaning of section 3(40) of title of ERISA, and whether the Trust is subject to state regulation at least to the extent provided in section 514(b)(6)(A), regardless of whether it is an employee benefit plan covered by title I of ERISA, because it is a MEWA within the meaning of section 3(40) of that title.

Whether the Virginia Automobile Dealers Association Employee Welfare Benefits Plan (the VADA Program) is a multiple employer welfare arrangement within the meaning of section 3(40) of title I of the Employee Retirement Income Security Act of 1974 (ERISA), and whether the VADA Program is subject to state regulation at least to the extent provided in section 514(b)(6)(A), regardless of whether it is an employee benefit plan covered by title I of ERISA, because it is a MEWA within the meaning of section 3(40) of that title.

Whether the Independent Contractors Association Welfare Benefit Trust (the Trust) is a multiple employer welfare arrangement (MEWA) within the meaning of section 3(40) of title I of ERISA, and whether the Trust is subject to state regulation at least to the extent provided in section 514(b)(6)(A), regardless of whether it is an employee benefit plan covered by title I of ERISA, because it is a MEWA within the meaning of section 3(40) of that title.

Whether the Kansas Society of Architects AIA Benefit Program Trust (the KSA Trust) is an employee welfare benefit plan within the meaning of section 3(1) of title I of ERISA and whether the KSA Trust is a multiple employer welfare arrangement (MEWA) within the meaning of section 3(40) of that title, and whether preemption provisions of ERISA preclude state regulation of the Trust at least to the extent provided in section 514(b)(6)(A).

Whether the proposed investment by two self-directed IRAs in a condominium unit violates the prohibited transaction provision of section 4975 of the Internal Revenue Code.

Whether The Derby Association Trust, Inc. (the Trust) is a multiple employer welfare arrangement (MEWA) within the meaning of section 3(40) of title I of ERISA, and whether the preemption provisions of section 514 of that title preempt state regulation of the Trust.

Whether the Group Rental Insurance Plan Medical Trust (the Trust) is a multiple employer welfare arrangement (MEWA) within the meaning of section 3(40) of title I of ERISA.

Whether purchases of stock of the Regis Group Incorporated (Regis) by various self-directed individual retirement accounts for which Robert W. Baird & Co. Incorporated (Baird), a wholly owned subsidiary of Regis, is the prototype sponsor is prohibited under the prohibited transaction provisions of section 4975 of the Internal Revenue Code of 1986 (the Code).

Whether the Alarm Association of Florida Health and Welfare Benefit Plan (the Plan) is an employee welfare benefit plan within the meaning of section 3(1) of title I of ERISA and whether the preemption provisions of section 514 of that title preempt state regulation of the Plan.

Whether MDPEBP is an employee benefit plan covered by title I of ERISA and whether the ability of the State of Texas to regulate MDPEBP is preempted by ERISA section 514(b)(6)(A).