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If the DOL no longer required employer associations to be bona fide (AKA have commonality and control over the plan), what entities would qualify as MEWA under the phrase "any other arrangement"? ------------------------------------------------------------------------------ People are correct in that the commonality requirement for pensions is not explicitly stated in ERISA. My thought, is congress may have ratified the DOL's position requiring employer associations to possess commonality and control by adopting the 1983 amendment defining a MEWA: Essentially, unless some entities would still be considered to be a non-EWBP MEWA without the commonality and control requirements, then the definition of employer association must require some form of commonality and control, otherwise part of the statute would be superfluous. Thoughts?