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Coverage

  • Opinion Letter 74-23

    A plan maintained by a union and funded only by contributions from union members is not covered under Title IV

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  • Opinion Letter 74-03

    Title IV excludes a defined benefit plan to the extent it is treated as an Individual account plan under 1002(35)(B).

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  • Opinion Letter 75-53

    Plan is governed by laws of Virgin Islands. Plan is not a qualified plan and is exempt from coverage under Title IV.

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  • Opinion Letter 79-06

    Plan of an entity chartered by the US Congress does not meet the Governmental plan coverage exemption.

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  • Opinion Letter 74-16

    Plans funded exclusively by individual insurance or annuity policies are exempt from coverage under Title IV.

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  • Opinion Letter 75-58

    The fact that a benefit formula may be modified by a plan amendment does not alter the defined benefit nature of the plan.  If the plan is amended to convert it to an individual account plan, it would be treated as terminated.

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  • Opinion Letter 77-155

    A plan operating under a favorable IRS determination letter is covered under Title IV.

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