Thank you. This is essentially our exact situation -- a typical unfunded, self-insured benefits plan. I usually deal with tax matters, but I was asked to take this on.
I am quite certain that the plan meets all the requirements for approval, but I am uncertain about the process for obtaining such approval. I reached out to my local branch DOL WHD branch, but have yet to hear back from them. Can you provide any insight into the process you followed? Did you have to request a private letter ruling?
*Edit: I got through to the local branch -- the person I spoke with didn't know the process either and said I would have to call back when someone else was there.