ERISA Advisory Opinions

A Service Provided by Niedweske Barber, P.C.

Opinions by Subject

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Index | P

		PARTICIPANT
79-08A		application of concept to particular fact pattern
99-04A		business owner as
81-54A 99-04A		definition of
94-17A		DOL guidance with respect to when an individual becomes a participant under a plan (29 CFR 2510.3-3(d)(1))
99-04A		owner-employee as
99-04A		self-employed individual as
99-04A		working owner as
		PARTICIPANT DIRECTED ACCOUNTS (404(c) PLANS)
		investment directives
96-02A		failure of trustees to follow
96-02A		where investment directive is imprudent
96-02A		definition of
		missing participants
96-02A		attempts to locate
96-02A		failure to locate
96-02A		last investment directive
96-02A		plan's obligations with respect to as an inherently factual question
		regulatory guidance (29 CFR Sec. 2550.404c-1)
96-02A		protection from liability
96-02A		losing protection from liability
96-02A		specific requirements
		PARTICIPANT LOANS
95-17A		credit cards, accessing through
95-17A		credit card issuer
95-17A		bank as fiduciary
95-17A		as fiduciary
95-17A		DOL belief regarding
95-17A		DOL unable to make determination regarding
95-17A		fiduciary considerations with respect to
95-17A		generally
95-17A		prohibited transaction provisions implicated by
95-17A		and statutory exemptions
95-17A		reasonable rate of interest
95-17A		DOL guidance with respect to
95-19A		application of regulatory guidance to fact pattern involving collectively bargained plans
		collectively bargained plans
95-19A		different loan terms for different collective bargaining units
95-19A		see also PARTICIPANT LOANS index heading, "DOL guidance with respect to" index subheading
		disclosure requirements
95-19A		collectively bargained plans, information which is required to be provided in plan documents
95-17A		purposes of statutory provision and regulatory guidance
95-17A		as not to encourage such participant loans
95-17A		fiduciaryÕs responsibility to assess and monitor participant loan programs
95-17A		to discourage diminution of participants retirement income
95-17A		to prevent losses to the plan
95-19A		reasonably equivalent basis
95-19A		regulation (29 CFR 2550.408b-1)
		see also PARTICIPANT LOANS index heading, "exemptions from prohibited transactions rules implicated by" index subheading
		see also PARTICIPANT LOANS index heading, "prohibited transactions provisions implicated by" index subheading
95-17A 95-19A		exemptions from prohibited transactions rules implicated by
		see also PARTICIPANT LOANS index heading, "credit cards, accessing through" index subheading
95-17A		prior DOL guidance with respect to (29 CFR 2550.408b-1)
84-06A		generally
96-01A		repayment through payroll deductions
96-01A		preemption of state laws relating to
95-17A 95-19A		prohibited transactions provisions implicated by
		see also PARTICIPANT LOANS index heading, "credit cards, accessing through" index subheading
95-17A		prior DOL guidance with respect to (29 CFR 2550.408b-1)
82-45A		prohibited transactions provisions in the IRC
		PARTICIPANT'S ABILITY TO DISPOSE OF INTEREST IN PLAN AT WILL
76-113 76-114		as factor considered in determining arrangement is not an employee pension benefit plan
		PARTICIPANT'S EXERCISE OF CONTROL OVER ASSETS IN THE PARTICIPANT'S ACCOUNT
75-81A		fiduciary implications
76-33		fiduciary standards
76-33		prohibited transaction standards, application to
		PARTICIPATION STANDARDS
94-16A		church plan elections under IRC Sec. 410(d)
76-02		inapplicable to employee welfare benefit plans
		PARTY IN INTEREST
97-23A		application of concept to DOL plan assets/plan investments regulation (29 CFR 2510.3-101)
75-147 77-83A 79-10A 79-37A 85-30A 85-31A 86-11A		application of concept to particular fact pattern
97-23A		application of concept to transactions between plan and third party administrator created by plan
97-23A		assets of the plan vs. assets of the entity
97-23A		conflict of interest considerations
76-120		credit union as
97-23A 97-24A		definition of
75-147		elements of concept
99-09A		employer as
81-78A		entity as not
76-102A		executor of decedent's estate as not constituting party in interest
84-01A 84-02A 99-05A		generally
75-94		government agency, as not including
97-23A		intra-plan transaction
97-23A		as not constituting transaction between the plan and a party in interest
99-09A		plan fiduciary as
76-59		plan's purchase of insurance through an agent who is also a plan participant
		prohibited transactions
80-43A		use of plan assets for the benefit of a party in interest
		see also PROHIBITED TRANSACTIONS index heading
		sale, exchange or transfer of plan assets
79-85A		transaction as not constituting as only the plan's manner of ownership is changed
99-05A		PASS-THROUGH CERTIFICATES
		PAYMENT OF BENEFITS AND PAYMENT OF REASONABLE ADMINISTRATIVE EXPENSES
94-39A		only permissible payments under Sec. 403(c)(1)
		PAYMENT OF COMPENSATION
94-14A		DOL guidance with respect to
		PAYMENT OF REASONABLE ADMINISTRATIVE EXPENSES AND PAYMENT OF BENEFITS
94-39A		only permissible payments under Sec. 403(c)(1)
		PAYMENTS FROM MULTIEMPLOYER FUND TO FORMER FUND OFFICIAL
81-83A		compensation
81-83A		prohibited transactions
81-83A		statutory exemptions
78-17A		PAYMENTS TO UNION MEMBERS WITH NO EMPLOYER-EMPLOYEE RELATIONSHIP TO UNION
		PAYROLL DEDUCTION
96-01A		for the repayment of loans from the plan
96-01A		preemption
		PAYROLL DEDUCTION CHECK-OFFS
75-144		as not constituting employee welfare benefit plan
		PAYROLL DEDUCTIONS EARMARKED FOR WELFARE BENEFIT PLAN PURPOSES
75-95		use of to pay union dues
		PAYROLL PRACTICE
93-02A 93-27A 94-40A		application of concept to particular fact pattern
80-44A		arrangement consituting
80-20A		arrangement not constituting
		benefits provided in addition to what is required by:
97-21A(FN6)		state-mandated disability benefits law
97-21A(FN6)		state-mandated disability insurance law
96-16A		circumstances in which the payroll practice exclusion does not apply
96-16A		cost-of-living adjustments, significance of
93-02A 94-12A(FN3) 94-14A		DOL guidance regarding
96-16A		description of
93-02A		disability, payments with respect to as
93-02A		non-occupational illness or injury
96-16A		distinguishing benefit plans from payroll practices
		employee welfare benefit plan
93-02A		certain practices not constituting
93-02A		concept not covering payroll practices
75-07A		general assets, not all payments from as constituting a payroll practice
81-71A 82-56A 83-37A 85-23A		generally
93-02A		income replacement program as
80-53A		job transfer supplemental payments
80-53A		payments (plus workers' compensation) equaling the employee's compensation
96-16A		pension payment offset (short of electing retirement), significance of
96-16A		preamble to regulation
94-40A		prior DOL guidance with respect to (AO 93-27A) (AO 93-20A) (AO 93-02A)
94-40A		regulations with respect to (Sec. 2510.3-1)
81-87A		salary continuation program as constituting
94-40A		sick pay plan as
80-53A		supplemental payments following return to work after disability
		PAYROLL SAVINGS PLANS
80-31A		arrangement not constituting
81-02A		PAY STATUS
		PBGC
		see PENSION BENEFIT GUARANTY CORPORATION index heading
		PENNSYLVANIA NON-PROFIT CORPORATION
93-03A		as church plan
		PENSION BENEFIT GUARANTY CORPORATION
93-01A		initial determination letter issued by as evidence of organization's church plan status
95-24A		reference to
95-07A		settlement between church plan and
		PENSION PLAN
79-60A		determination of based on surrounding circumstances
81-35A		frozen prior to ERISA but related trust continued in existence
		see also EMPLOYEE PENSION BENEFIT PLAN index heading
95-24A		termination of
		PENSION PLAN VERSUS SEVERANCE PLAN
		see SEVERANCE PAY and associated index headings
		PENSION PLAN VERSUS WELFARE PLAN
81-16A		discussion of
97-24A		PERCENTAGE TEST
		PERFORMANCE-BASED COMPENSATION
99-16A		as implicating ERISA's fiduciary standards
99-16A		payment of as constituting prohibited transaction
		PHILADELPHIA, ARCHDIOCESE OF
94-05A 94-06A		as a geographical and hierarchical division of a church
		PLAN ADMINISTRATOR
80-30A		generally
		PLAN AMENDMENTS
94-42A		graduated termination of floor-offset arrangement
96-06A		PLAN AMENDMENTS ASSURING MINIMUM PENSION BENEFITS
		PLAN ASSETS
96-12A		29 CFR sec. 2510.3-102
96-12A(FN4)		DOL's non-enforcement policy
		absence of
93-02A(FN1)		prior DOL guidance (AO 92-24)
78-06A		allocation of, upon termination of pension plan
76-17A		annuities held by insurance company as
99-08A		assets of a trust as not constituting
99-08A		beneficial interest in
93-02A(FN1)		checking accounts
		DOL guidance
94-31A		beneficial interest depends largely on:
94-31A		employer expressing intent to grant such an interest
94-31A		employer actions or representations leading to conclusion that funds secure benefits or are plan assets
94-31A		ordinary notions of property rights, as identified on basis of
94-31A		participant contributions to a plan (29 CFR 2510.3-102)
94-31A		plan investments in other entities (29 CFR 2510.3-101)
		prior DOL guidance with respect to
94-31A		beneficial interest exists where bank account established in the name of the plan (AO 92-24A)
94-31A		beneficial interest exists where plan documentation specifically indicates that separately-maintained funds belong to the plan (AO 92-24A)
94-31A		application of concept to particular fact pattern (AO 84-10)
94-31A		beneficial interest exists where trust established on behalf of plan (AO 92-24A)
94-31A		beneficial interest not created by mere segregation of fund to facilitate plan administration (AO 92-24A)
94-31A		beneficial interest not created by purchase of stop-loss insurance policy (AO 92-02A)
94-31A		factors considered in determining
83-51A 99-05A		generally
94-31A		identification of
94-31A		contract or other instrument, as requiring consideration of
94-31A		actions and representations, as requiring consideration of
75-79A		insurance policy, rather than the underlying assets of the insurance company
75-80A		owned outside of the United States
94-39A		payment of benefits and payment of reasonable administrative expenses
94-39A		only permissible uses under Sec. 403(c)(1)
77-92A		premium payments made from employer's general assets as not constituting
77-92A		scenario not constituting prohibited transaction
		reversion of to employers upon termination of multiemployer plan
94-39A		anti-inurement rule
		exclusive purpose rule
94-39A		Sec. 403(c)(1)
94-39A		exceptions to
94-39A		fiduciary considerations, generally
94-39A		prohibitions on
		see also ASSETS OF THE PLAN index heading
96-12A		segregating from employer's general assets
92-22A		split-dollar life insurance policy, application of concept to cash value element of
92-02A		stop-loss insurance policy as not constituting
		types of property defined as
94-31A		DOL having issued no guidance on topic of
75-94		use of to defray costs of responding to governmental request for information
		versus general assets of the employer
93-02A(FN1)		prior DOL guidance (AO 92-24)
93-02A(FN1)		welfare benefit plans
		PLAN ASSETS REGULATION (29 CFR Sec. 2510.3-101)
		application to:
95-04A		small business investment companies
95-04A		initial capitalization
95-04A		management rights, exercise of
95-04A		as a separate entity, wholly owned by venture capital operating company
95-04A		description of
95-04A		equity interest, plan's investment in
95-04A		assets as including equity interest and underlying assets
95-04A		look through rule, premise of
95-04A		as distinguishing between pooled investment vehicle and operating companies
95-04A		operating companies
95-04A		definition of
		as exception
95-04A		exception as applicable to venture capital operating company
95-04A		generally
95-04A		operating companies and pooled investment vehicle, difference between
95-04A		pooled investment vehicle
95-04A		pooled investment vehicle and operating companies, difference between
95-04A		venture capital operating company
95-04A		as exception
95-04A		qualification requirements of
		PLAN ASSETS/PLAN INVESTMENTS
97-23A		DOL regulation (29 CFR 2510.3-101)
		PLAN COVERING PARTICIPANTS ABOVE A CERTAIN PAY LEVEL
89-22A		unfunded
89-22A		excess benefit plan
		PLAN DESIGNED TO ENCOURAGE PURCHASE OF SPONSOR'S STOCK
79-50A		as constituting employee pension benefit plan
		PLAN INVESTMENTS
75-83A		absence of list of appropriate plan investments
98-04A		generally
82-49A		in futures contracts
75-83A		in World Bank bonds
		PLAN LOANS
		see PARTICIPANT LOANS index heading
		PLAN OFFICIAL
79-10A		bonding requirements
		PLAN SERVICES
97-16A		payment of fees to third party administrator for
		PLAN SPONSOR
95-24A(FN4)		definition of
		PLAN'S ACQUISITION OF INTEREST IN ACCOUNTS OF COMPANY WHICH IS A PARTY IN INTEREST TO THE PLAN
79-26A		prohibited transactions
79-26A		statutory exemptions
		PLAN'S ACQUISITION OF INTEREST IN INSURANCE COMPANY WHICH IS A PARTY IN INTEREST
79-29A		prohibited transaction
		PLAN'S ACQUISITION OF SPONSOR'S STOCK FROM PARTY IN INTEREST
76-88		prohibited transactions
76-88		statutory exemptions
76-62		PLAN'S INVESTMENT IN A BANK ONE OF THE DIRECTORS OF WHICH IS ALSO A PLAN TRUSTEE
76-62 76-76		prohibited transactions
		PLAN'S INVESTMENT IN INSTRUMENTS ISSUED BY PARTICIPATING EMPLOYERS
79-25A		prohibited transactions
79-25A		statutory exemptions
		PLANS NOT IN COMPLIANCE WITH CERTAIN SECTIONS OF ERISA
77-77A		no departmental action to be taken with respect to such plans
		PLAN SPONSOR
88-06A		discussion of
		PLAN SPONSOR'S RECEIPT OF PAYMENT FOR ASSIGNMENT OF LEASEHOLD INTEREST
85-33A		prohibited transactions
		PLAN'S PURCHASE OF INSURANCE THROUGH AN AGENT WHO IS ALSO A PLAN PARTICIPANT
76-59		party in interest
76-59		application of concept
		PLAN'S PURCHASE OF LAND FROM DECEDENT'S ESTATE WHERE ESTATE'S EXECUTOR WAS A PLAN TRUSTEE
76-102A		prohibited transaction, as not constituting
		PLAN'S PURCHASE OF STOCK OF THE SPONSOR FROM DIRECTORS OF THE SPONSOR
77-30A		prohibited transactions
77-30A		statutory exemptions
		PLAN'S RETAINING OF AN ATTORNEY WHO IS ALSO UNION'S COUNSEL
76-91		prohibited transactions
76-91		statutory exemptions
		PLAN'S SALE OF SECURITIES TO PLAN PARTICIPANTS
79-57A		prohibited transactions
79-57A		statutory exemptions
		PLAN'S SALE OF STOCK OF SPONSORING EMPLOYER TO RELATED EMPLOYER
79-23A 79-68		prohibited transactions
79-23A		statutory exemptions
		PLAN'S SALE OF STOCK OF SPONSORING EMPLOYER TO THE SPONSORING EMPLOYER
80-13A		prohibited transactions
80-13A		statutory exemptions
		PLAN'S SALE OF STOCK TO PLAN SPONSOR
80-48A		where the plan owns a controlling interest in stock of corporation
80-48A		certain prohibitions not effective until June 30, 1984
		PLAN'S SALE TO SPONSORING EMPLOYER OF DEVELOPED PROPERTY REPRESENTING A SIGNIFICANT PORTION OF PLAN ASSETS
76-132		adequate consideration
		PLAN TERMINATION EXPENSES
97-03A		amendment of plan document to allow payment of
97-03A		as appropriate expenses of the plan
97-03A		fiduciary considerations with respect to
01-01A		generally
97-03A		plan document silent as to payment of
97-03A		prohibited transactions provisions implicated with respect to payment of
		regulatory guidance issued with respect to:
97-03A		necessary service
97-03A		reasonable compensation
97-03A		reasonable contract or arrangement
97-03A		statutory exemption under ERISA Sec. 408(b)(2) as affecting propriety of payment of
84-34A 95-06A(FN3)		PLAN WITHOUT EMPLOYEES
81-88A		exception not applicable to particular fact pattern
97-20A		POLICE OFFICERS, ASSOCIATION OF
		POLICE OFFICERS, WELFARE BENEFIT PLAN COVERING
79-38A		as covered under Title I
		see also GOVERNMENTAL PLANS index heading
		POLITICAL SUBDIVISION
97-20A 97-26A		generally
96-05A		POOLED CUSTODIAL ACCOUNT
		see also MULTIPLE EMPLOYER WELFARE ARRANGEMENT index heading
		POOLED INVESTMENT FUNDS
96-15A		concept implicating prohibited transaction rules
		see also PROHIBITED TRANSACTIONS index heading
96-15A		concept implicating statutory exemption
		see also PROHIBITED TRANSACTIONS index heading
95-04A		POOLED INVESTMENT VEHICLE
		PREDECESSOR EMPLOYER
76-94A		obligations of acquiring employer with respect to pension plan sponsored by
		PREEMPTION
87-09A		application of concept to particular fact pattern
80-60A		California Confidentiality of Medical Information Act
79-30A		California unclaimed property law
87-09A 96-01A 96-03A 96-06A		case law, discussion of
96-03A 96-04A		congressional intent
84-06A		Colorado Consumer Credit Code
79-06A		Connecticut state law
96-06A 97-21A		definition (statutory) of
97-21A		disability insurance, state-mandated
97-21A		disability payments, state-mandated
81-62A 96-03A 96-04A 96-27A 96-41A		discussion of
97-21A		exception to, where applicable state law allows employer to establish its own plan as an alternative to participating in state-mandated disability program
97-21A		exception to, with respect to state enforcement of state requirements
81-63A		Florida's predetermination requirements
81-31A 81-44A 82-57A 84-18A 84-26A 84-39A 88-05A 93-04A 93-05A 96-01A		generally
96-04A		health insurance benefits
96-04A		state laws regarding
81-70A		Illinois interest rate laws
80-03A		Illinois marital property laws
78-32A		Illinois Uniform Disposition of Unclaimed Property Act
		insurance, banking, or securities
94-41A		laws regulating not preempted
96-03A 96-04A		insurance, state laws regulating
		Javits, Senator
94-41A		statement of (120 Cong. Rec. S15751, August 22, 1974)
78-02A		Kentucky health insurance conversion requirement
		Knox-Keene Act
78-03A 96-06A		case law interpreting
96-06A		distinction between fully insured and self insured irrelevant
96-04A		laws exempt from
79-90A		levy issued by state judicial or administrative agency
		life insurance benefits
96-03A		state law requiring continuation of
79-35A		Massachusetts criminal laws
82-16A		Minnesota usury laws
94-20A(FN1) 97-14A		multiple employer welfare arrangements
82-06A		New Hampshire benefits continuation law
		New York
83-39A		abandoned property law
80-47A 80-54A		insurance law
		law requiring plans to obtain authorization for wage deferrals
94-27A		application of preemption concepts to particular fact pattern
94-27A		description of
94-27A		text of
80-17A		savings bank law
96-01A		participant loans, repayment of
96-03A 96-04A		purposes of
		relates to
94-27A		case law having interpreted term broadly
94-27A		discussion of case law
97-14A		savings clause
		self-executing
94-27A		ERISA preemption provision as
86-05A		state and municipal taxation of elective deferrals in qualified plans
75-129A		state filing requirements
76-90		state health care service plan act
		state laws
94-27A		definition of
88-17A		state law prohibiting payroll deductions to fund employee benefit plans
75-143		state law regulating health care contractors
75-128		state law relating to self-insured medical plans
75-22 76-84		state prepaid health care act
		state unclaimed property statutes
94-41A		application of preemption concept to particular fact pattern
94-41A		Texas state law
79-30A		California's unclaimed property law
94-41A(FN3)		case law discussing
		see UNCLAIMED PROPERTY STATUTES index heading
94-27A 94-41A		statutory text of provision
78-03A		Utah non-insured welfare plan law
79-31A		Washington's insurance laws
		PREMIUM CONVERSION PLAN
94-15A(FN5)		as not included in ERISA's definition of employee welfare benefit plan
		PREPAID LEGAL SERVICES PLAN
81-61A		as constituting employee welfare benefit plan
79-46A		generally
75-02A		included in definition of employee welfare benefit plan
		see also GROUP LEGAL SERVICES PROGRAM index heading
		PRESCRIPTION DRUG PLAN
85-21A		application of employee welfare benefit plan standards to
		PROFESSIONAL GOLFERS ASSOCIATION OF AMERICA, PLAN SPONSORED BY
88-07A		application of employee pension benefit plan standards to
		PROFIT SHARING PLAN
75-12A		as constituting employee pension benefit plan
		PROHIBITED TRANSACTION EXEMPTION 75-1
87-06A		extensions of credit
86-12A		extensions of credit in connection with securities transactions
98-06A		PROHIBITED TRANSACTION CLASS EXEMPTION 77-3
84-08A		investment advisor
		PROHIBITED TRANSACTION EXEMPTION 77-4
93-12A 93-13A 94-35A		application of
		disclosure requirements
94-35A		prospectus
94-35A		information in lieu of prospectus
94-35A		requirements
94-35A		discussion of
94-35A		federal register cite (42 FR 18732, April 8, 1977)
		offering of securities
94-35A(FN1)		Securities Act of 1933, registration requirements of
		public offerings
94-35A(FN1)		Securities Act of 1933, registration requirements of
94-35A(FN3)		purchase of shares in mutual fund other than for cash, relief unavailable for
93-26A		relief available to IRAs and H.R. 10 plans
94-35A		second fiduciary
79-26A 80-30A		PROHIBITED TRANSACTION EXEMPTION 77-9
		PROHIBITED TRANSACTION EXEMPTION 78-19
80-67A		ownership interest in entity which is allocated to separate account will not cause the entity to become an affiliate of the company
		PROHIBITED TRANSACTION EXEMPTION 79-1
82-12A		custodian
82-12A		plan administrator
82-12A		trustee
83-19A 83-59A		PROHIBITED TRANSACTION EXEMPTION 79-41
84-30A		PROHIBITED TRANSACTION EXEMPTION 79-60
		PROHIBITED TRANSACTION EXEMPTION 80-26
94-28A		discussion of
94-28A		extension of credit
94-28A		lending of money
94-28A		qualified domestic relations order, and loans made to the plan to satisfy obligations under
94-28A		repayment of loan
82-41A 83-12A		PROHIBITED TRANSACTION EXEMPTION 80-51
96-15A		as amended by PTE 91-38
		PROHIBITED TRANSACTION EXEMPTION 81-8
92-25A		furnishing of financial statements to a plan
84-33A		PROHIBITED TRANSACTION EXEMPTION 83-1
		PROHIBITED TRANSACTION EXEMPTION 84-14
99-11A		Qualified Professional Asset Manager under
99-11A		status of merger with newly-formed corporation under
		PROHIBITED TRANSACTION EXEMPTION 91-38
96-15A		as amending PTE 80-51
96-15A		collective investment funds as parties in interest, conditions with respect to
		PROHIBITED TRANSACTION EXEMPTION 92-6
98-07A		definition of relative under
98-07A		individual life insurance contract under
98-03A		PROHIBITED TRANSACTION EXEMPTION 97-11
98-06A		PROHIBITED TRANSACTION EXEMPTION 97-41
		PROHIBITED TRANSACTIONS
78-19A		acquisition and sale of qualifying employer securities between eligible individual account plan and the employer
84-20A		acquisition, sale or lease of qualifying employer real property
77-01A 77-16A		acquisition of real property and lease back
79-79A		amendment of group annuity contract
83-20A		application of standards to investment management and advisory services
81-45A 83-11A 84-09A 85-24A 85-26A 85-43A		application to particular fact pattern
99-17A		appointment of and terms of trustees
79-72A		apprenticeship and training fund
97-15A		assets of the plan, certain fiduciary transactions as not constituting
76-36		bonds, prohibited transactions provisions inapplicable to certain sales of
75-137		certain provisions not applying before June 30, 1977
76-103		collectively-bargained plan's hiring of union negotiator to conduct training programs
75-21		compensation of plan official also serving as employee of plan sponsor
79-42A		compensation of plan official also serving as trustee
79-59A		compensation of trustee
75-145		compensation of trustee who is also receiving compensation from employer
99-17A		congressional intent
80-59A		consulting services
81-69A		contribution of an option (to a condominium) by the sponsoring employer to a pension plan
82-04A		controlled group of corporations
		convertible debentures
79-45A		as qualifying employer securities
75-103		credit union and employee benefit plan, transaction between
76-38		credit union share accounts, investment in at the direction of participants
77-45A		custodial services (and compensation with respect to)
97-24A		dealing with assets of the plan for the benefit of a plan fiduciary
76-72		debentures; acquisition, sale, or assignment of
79-58A 81-23A		deferred compensation, receipt of after June 30, 1977 for services provided before that date
77-91A		delinquent employer contributions
76-91		delinquent employer contributions, compensation for pursuing
88-03A		direct expenses
		discount brokerage services (in-house)
85-15A 85-16A		provision of to plans by a bank which also serves as trustee
79-28A 80-01A		divesting the plan of qualifying employer securities
97-19A		DOL regulation 2550.408b-2(e)(3)
		double compensation of fiduciaries
78-08A		institutions covered by TIAA-CREF
		see also "direct expenses" index subheading
81-42A 81-72A		early redemption penalties
79-77A		eligible individual account plan, arrangement as constituting
79-56A		eligible individual account plan, thrift plan as
		Employee Stock Ownership Plan
80-46A		prohibited transactions provisions implicated by establishment of
85-19A		employee/trustee of plan sponsor receiving compensation for services to the plan as trustee (29 CFR Sec. 550.408c-2), statutory exemptions inapplicable to
81-20A		ERISA
97-19A		ERISA Sec. 406(b)(3)
78-22A		exchange of stock between plan and plan sponsor
		fiduciary
97-23A		dealing with assets of the plan for his or her own account or interest
97-23A		dealing with assets of the plan where interests are adverse to those of the plan or its participants
97-23A		receiving personal consideration from a party dealing with the plan with respect to assets of the plan
97-15A		fiduciary's personal account
		fiduciary's personal account and assets of the plan
97-19A		statutory exemption
82-11A		5-percent rule
77-45A		fund trustee also serving as custodian
99-09A		furnishing of goods, services, or facilities
81-04A 81-34A 82-22A 82-31A 83-20A 83-44A 88-14A 92-08A 92-27A 93-06A 99-03A 00-10A 01-09A		generally
		Harvard
80-25A		appointment of Harvard as trustee and contributions by Harvard to its own pension plan
97-06A		holding of employer security or employer real property
86-20A 86-21A		incentive compensation, payment of to plan's investment advisor
		individual retirement account
82-65A		application to of IRC prohibited transactions provisions
86-28A		custodian's purchase and sale of stock of company affiliated with custodian
81-29A		investment in thrift certificates of entity which also serves as trustee and custodian
82-08A		loans
79-76A		institutional trustee's purchase of sponsor's CDs with plan assets
96-08A		in the IRC
81-20A 82-24A		generally
82-65A 85-17A 85-18A		individual retirement account
85-18A		Keogh plans
82-45A		participant loans
96-08A		relationship to ERISA exemptions
84-04A		investment advice
77-44A		investment advisory services (and compensation with respect to) provided by parties in interest and disqualified persons
84-03A		investment consulting services
83-52A		investment management services, furnishing of
83-61A		investment manager
77-31A		joint purchase of id cards by union local and affiliated welfare plans, as not constituting prohibited transaction
77-64A 77-65A		litigation expenses, reimbursement of
81-66A		loan by plan to sponsoring employer
		loans
84-44A		transformation of into a prohibited transaction
77-91A		loans from multiple employer plans to participating employers
77-47A		loan from pension plan to union local
77-47A		prohibited transactions provisions in the IRC
79-73A		loan to plan by bank which serves as trustee to the plan
79-43A		locating -- for a fee -- promissory notes secured by deeds
79-43A		prohibited transactions in the IRC
79-47A		merger of two pension plans
75-103		occurring indirectly
		office space
76-91		plan's lease and subletting of
77-91A		office space and administrative services
75-105		participant loans, where the participant is also a plan trustee
76-33		participant's exercise of control over assets in account
79-13A		as not prohibiting particular transaction
		see also PARTY IN INTEREST index heading
88-13A		payment of compensation to a trustee of a benefit fund who is also an employee of an organization which at one time contributed to the benefit fund
81-52A		payment of death benefit to widow of fund manager in the absence of legal obligation
97-15A		payment of fees by mutual fund (in which the plan invests) to a bank (which serves as a plan trustee)
81-83A		payments from multiemployer fund to former fund official
86-02A		payments to affiliated company for providing services to the plan as not constituting
86-01A		payments to plan administrator for services performed as not constituting
99-16A		performance-based compensation
75-108		plan loans to employees
76-15		plan official also serving as investment manager
79-26A		plan's acquisition of interest in accounts of company which is a party in interest to the plan
79-29A		plan's acquisition of interest in insurance company which is a party in interest
76-88		plan's acquisition of sponsor's stock from party in interest
87-04A		plan's acquisition of stock from the plan fiduciary's parent
76-62 76-76		plan's investment in a bank one of the directors of which is also a plan trustee
79-25A		plan's investment in instruments issued by participating employers
76-16		plan's purchase of employer/sponsor's securities
92-23A		plan's purchase of securities issued by a company which serves as the plan's trustee
77-30A		plan's purchase of stock of the sponsor from directors of the sponsor
76-91		plan's retaining of an attorney who is also union's counsel
79-57A		plan's sale of securities to plan participants
76-68 79-23A		plan's sale of stock of sponsoring employer to related employer
80-13A		plan's sale of stock of sponsoring employer to the sponsoring employer
		plan's sale of stock to company
77-06A		as not constituting qualifying employer securities
85-33A		plan sponsor's receipt of payment for assignment of leasehold interest
77-92A		premium payments made from employer's general assets, as not constituting prohibited transaction
86-11A		property management and leasing services by a party with a connection to the plan as not constituting a prohibited transaction
79-11A		provision of securities lending services to plans by trustee
82-39A 82-52A		provision of services to a plan
01-10A		reasonable compensation
99-09A		recusal from decision-making as method to avoid
77-02A		redemption of shares
88-03A		reimbursement of compensation paid by a service provider to its employees
80-57A		sale and lease back
77-91A		sale and lease of goods
97-24A		sale of property between plan and party in interest
77-48A		where the property sold was owned by the plan on June 30, 1974
77-83A		sale to plan of participation interests in loans
		see also CLASS ACTION LITIGATION, SETTLEMENT OF index heading
		see also PARTICIPANT LOANS index heading
		see also SERVICE FEES index heading
		services to a trust company rather than a benefit plan
82-55A		as not implicating prohibited transactions provisions
99-12A		settlement of litigation, payment of monies in
77-03A		sponsor's creditor serving as plan's trustee and custodian
76-14		sponsor's lease of plan's real property
		statutory exemptions
78-19A		acquisition and sale of qualifying employer securities between eligible individual account plan and the employer
77-01A 77-16A		acquisition of real property and lease back
79-72A		apprenticeship and training fund
97-23A		certain arrangements with party in interest for office space, legal services, accounting services, or other services where no more than reasonable compensation is paid
76-103		collectively-bargained plan's hiring of union negotiator to conduct training programs
75-21A		compensation of plan official also serving as employee of plan sponsor
79-42A		compensation of plan official also serving as trustee
79-59A		compensation of trustee
75-145		compensation of trustee who is also receiving compensation from employer
80-59A		consulting services
77-45A		custodial services (and compensation with respect to)
76-91		delinquent employer contributions, compensation for pursuing
88-03A		direct expenses
81-42A 81-72A		early redemption penalties
85-19A		employee/trustee of plan sponsor receiving compensation for services to the plan as trustee (29 CFR Sec. 550.408c-2), statutory exemptions inapplicable to
78-22A		exchange of stock between plan and plan sponsor
82-11A		5-percent rule
77-45A		fund trustee also serving as custodian
81-04A 82-22A 82-31A 83-45A 84-20A 85-15A 85-16A 86-01A 86-02A 86-11A 97-06A 97-23A 99-09A 01-09A		generally
79-76A		institutional trustee's purchase of sponsor's CDs with plan assets
84-04A		investment advice
83-52A		investment management services, furnishing of
83-61A		investment manager
79-47A		merger of two pension plans
		office space
76-91		plan's lease and subletting of
76-91		statutory exemption for certain acts occurring before June 30, 1984
75-105		participant loans, where the participant is also a plan trustee
88-13A		payment of compensation to a trustee of a benefit fund who is also an employee of an organization which at one time contributed to the benefit fund
01-10A		payment of fees to third party administrator which also is the ERISA plan sponsor
81-83A		payments from multiemployer fund to former fund official
		payment to trustee
80-58A		of per diem allowance in lieu of actual-expense reimbursement
75-108		plan loans to employees
76-15		plan official also serving as investment manager
79-26A		plan's acquisition of interest in accounts of company which is a party in interest to the plan
76-88		plan's acquisition of sponsor's stock from party in interest
87-04A		plan's acquisition of stock from the plan fiduciary's parent
79-25A		plan's investment in instruments issued by participating employers
76-16		plan's purchase of employer/sponsor's securities
77-30A		plan's purchase of stock of the sponsor from directors of the sponsor
76-91		plan's retaining of an attorney who is also union's counsel
79-57A		plan's sale of securities to plan participants
79-23A		plan's sale of stock of sponsoring employer to related employer
		plan's sale of stock to company
77-06A		as not constituting qualifying employer securities
81-46A		proposed activity as statutorily exempt from prohibited transaction rules
82-39A 82-52A		provision of services to a plan
88-03A		reimbursement of compensation paid by a service provider to its employees
80-57A		sale and lease back
84-28A		sale of property between plan and party in interest
		see also CLASS ACTION LITIGATION, SETTLEMENT OF index heading
		see also PARTICIPANT LOANS index heading
97-23A		services purchased by a plan from another plan
97-23A		services purchased by a plan from an entity whose assets are considered plan assets
88-02A		sweep services
82-26A		trust and brokerage services
88-02A		sweep services
79-56A		thrift plan as eligible individual account plan
82-36A		trademarks, sale of
85-40A		transfer of funds from a pension plan to a welfare plan as not constituting prohibited transaction
79-79A		transfer of plan assets from one account to another
83-38A		transfer of assets from pooled separate accounts to a general account, application of prohibited transactions standards to
82-26A		trust and brokerage services
97-15A		trustee's compensation benefiting the plan rather than the trustee
82-62A		trustee services
97-23A		with respect to third party administrator created by plan providing services to other employers which participate in the plan
97-23A		as the furnishing of goods, services, or facilities between the plan and a party in interest
97-23A		and statutory exemption to prohibited transaction rules
97-23A		as the transfer to or use by of assets of the plan with respect to a party in interest
97-23A		third party administrator created by plan providing services to other plans with prior relationships to plan
97-23A		prior exemptive relief granted with respect to
97-23A		third party administrator created by plan providing services to the plan
84-01A 84-02A		transfer of assets from welfare plan to pension plan
97-24A		transfer to or use by or beneficial interest in assets of the plan with respect to party in interest
80-43A		use of plan assets for the benefit of a party in interest
		with respect to certain insurance policies
97-24A		on question of applying separately or in the aggregate
81-46A		PROPOSED ACTIVITY AS STATUTORILY EXEMPT FROM PROHIBITED TRANSACTION RULES
		PROSPECTUS
94-35A		disclosure requirements
94-35A		PTE 77-4
94-35A		information in lieu of
94-35A		requirements
		PROTOTYPE PLANS
77-11A		application of fiduciary standards to
77-10A		coverage under ERISA
		see also GOVERNMENTAL PLANS index heading
		PROVISION OF INVESTMENT SERVICES TO BENEFIT FUND
80-28A		compensation with respect to
		PROVISION OF SECURITIES LENDING SERVICES TO PLANS BY TRUSTEE
79-11A		prohibited transactions
		PROVISION OF SERVICES TO A PLAN
82-39A 82-52A		prohibited transactions
82-39A 82-52A		statutory exemptions
76-56A		PUBLIC EMPLOYEE PENSIONS
		PUBLIC HOSPITAL
97-26A		plan covering employees of
		PUBLIC OFFERINGS
94-35A(FN1)		Securities Act of 1933, registration requirements of
		PUERTO RICO
82-23A		certain laws of preempted
75-20A 96-01A		defined as state under ERISA
82-23A		income tax laws of not preempted
78-06A		plan maintained within, as covered by ERISA
96-01A		state law prohibiting payroll deductions to repay plan loans
96-01A		preemption
88-17A		state law prohibiting payroll deductions to fund employee benefit plans
88-17A		preemption
98-06A		PURCHASE VS. EXCHANGE