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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**1994**
AO/ Date/ Reference	Recipient	Description of Request
1994-27A 07/14/1994 514(a)	Mr. Leonard P. Larrabee, III Dreyfus Service Corporation 200 Park Avenue New York, N.Y. 10166	Whether New York Labor Law section 193 (McKinney 1986) (Section 193) is preempted by section 514(a) of Title I of ERISA to the extent that Section 193 requires employee benefit plans covered by Title I of ERISA to secure written authorization for employee elective deferrals from their wages.
1994-26A 07/11/1994 2510.3-1(j) 3(1)	Ms. Catherine A. Powers Benefits Attorney Air Line Pilots Association 535 Herndon Parkway P.O. Box 1169 Herndon, Virginia 22070	Whether the Air Line Pilots Association, International Group Loss of License Disability Income and the ALPA Group Extended Total Disability Income Insurance Plan are "employee welfare benefit plans" within the meaning of section 3(1) of ERISA.
1994-25A 07/11/1994 2510.3-1(j) 3(1)	Ms. Catherine A. Powers Benefits Attorney Air Line Pilots Association 535 Herndon Parkway P.O. Box 1169 Herndon, Virginia 22070	Whether the Air Line Pilots Association, International (ALPA) Group Legal Expense Insurance Plan is an "employee welfare benefit plan" within the meaning of section 3(1) of ERISA.
1994-24A 07/01/1994 2510.3-1(j) 3(1)	Ms. Catherine A. Powers Benefits Attorney Air Line Pilots Association 535 Herndon Parkway P.O. Box 1169 Herndon, Virginia 22070	Whether the Air Line Pilots Association, International Group Accidental Death and Dismemberment Insurance Plan is an "employee welfare benefit plan" within the meaning of section 3(1) of ERISA.
1994-23A 07/01/1994 2510.3-1(j) 3(1)	Ms. Catherine A. Powers Benefits Attorney Air Line Pilots Association 535 Herndon Parkway P.O. Box 1169 Herndon, Virginia 22070	Whether the Air Line Pilots Association, International (ALPA), Group Accident and Sickness Insurance Plan is an "employee welfare benefit plan" within the meaning of section 3(1) of ERISA.
1994-22A 07/01/1994 2510.3-1(j) 3(1)	Ms. Catherine A. Powers Benefits Attorney Air Line Pilots Association 535 Herndon Parkway P.O. Box 1169 Herndon, Virginia 22070	Whether the Air Line Pilots Association, International (ALPA) Group Term Life Insurance Plan is an "employee welfare benefit plan" within the meaning of section 3(1) of ERISA.
1994-21A 06/17/1994 3(32)	Ms. Theresa L. Holmes Corporate Counsel Lexington Fayette Urban County Government 200 East Main Street Lexington, Kentucky 40507	Whether inclusion of employees of The Carnegie Center for Literacy and Learning in the County Employees Retirement Systems (CERS), a retirement system administered by the Kentucky Retirement Systems to provide retirement benefits to employees of counties and school boards in the State of Kentucky, would affect the status of CERS as a governmental plan within the meaning of section 3(32) of Title I of ERISA.
1994-20A 06/17/1994 3(40) 514(b)	Mr. Alfred W. Gross Deputy Commissioner Virginia Bureau of Insurance Box 1157 Richmond, Virginia 23209	Whether the Freedom Spirit program offered by Unitec Association which is insured by The Centennial Life Insurance Company is a multiple employer welfare arrangement (MEWA) within the meaning of section 3(40) of Title I of ERISA.
1994-19A 06/13/1994 3(32) 4(b)(1)	Mr. David R. Levin Reish & Luftman 11 Dupont Circle, Suite 775 Washington, D.C. 20036-1207	Whether the Appalachian Regional Commission Pension Plan is a governmental plan within the meaning of Title I of ERISA and thus is excluded by section 4(b)(1) from coverage by the requirements of Title I of ERISA.
1994-18A 05/23/1994 3(33) 4(b)(2)	Ms. Melissa B. Rasman Dechert Price & Rhoads 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, Pennsylvania 19103-2793	Whether certain benefit arrangements for the Theological Seminary of the Presbyterian Church (U.S.A.) a/k/a Princeton Theological Seminary's employees are church plans within the meaning of section 3(33) of Title I of ERISA.