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DOL Contact Number/ERISA bonding questions


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Greetings,

Does anyone have a good contact at the DOL that they could share?

I have been looking into the question of when ERISA bonding is required under Section 412 with respect to a TPA that collects premiums from plan sponsor and remits to the carrier (note: TPA does not pay claims). My feeling is that these monies are not "plan funds" that trigger the bonding requirement until they are in the hands of the carrier, and thus the TPA does not need to have an ERISA bond in place.

I base this mostly on Section 2580.412-5 "Determining when 'funds or other property" belong to a plan.

https://www.law.cornell.edu/cfr/text/29/2580.412-5

Any information, whether it be a contact # or experience relating to the above issue, would be most appreciated.

Thank you.

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