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.

Data Dictionary

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**1975**
AO/ Date/ Reference	Recipient	Description of Request
1975-28 10/17/1975 3(33)	Anonymous	Whether the Cemeteries Association of the Diocese Revised Pension Plan is covered under ERISA.
1975-27 07/21/1975 3(33)	Anonymous	Whether a pension plan for employees of a home for disadvantaged children operated under the auspices of the Church is covered by ERISA.
1975-25 02/13/1975 3(32)	Anonymous	Whether ERISA applies to a pension plan established by the City Fire Department for its employees, specifically regarding continued pension benefits in the event of a natural disaster.
1975-24 10/21/1975 3(21) 404 412	Anonymous	Whether a person who is both a trustee and a participant in an employee benefit plan should be considered to be a fiduciary with respect to the plan under section 404(c) of ERISA if such person is a trustee with respect to both his individual account and the individual accounts or other plan participants and beneficiaries.
1975-22 07/18/1975 4(b) 514	Anonymous	Whether Prepaid Health Care Act [statute] has been preempted by ERISA and, if so, the extent of such preemption.
1975-21 03/04/1975 3(14) 406 414	Anonymous	Whether section 408(c) provides an exemption from section 406's prohibited transaction rules for such fiduciaries, in light of IRS Technical Information Release (TIR 1329) aligning with ERISA's provisions.
1975-20 01/21/1975	Anonymous	Applicability of ERISA to an employee welfare benefit plan maintained in Puerto Rico.
1975-19 10/10/1975 3(3)	Anonymous	Whether a plan trustee must be bonded if he is the sole plan participant and whether, if there are two participants in the plan and one is the trustee but can exercise control of the account’s assets, either or both must be bonded.
1975-18 02/15/1975	Anonymous	Request for an exemption from the definition of “employee” for fulltime student employees under ERISA.
1975-17 12/17/1975 3(2)	Anonymous	Whether the Secretary of Labor has the authority under ERISA to grant a three- or four-year delay in the application of minimum participation standards for pension plans, specifically regarding the inclusion of employees with one year of service.