Guest erisafried Posted November 25, 2003 Posted November 25, 2003 I am engaging in some friendly discussion with our friends at the DOL regarding the use of what may or may not be a premium refund from an experience-rated health insurance contract. In the course of researching the issues involved here, I have come across several references to an internal DOL memorandum written by Risa Sandler in 1994 which discusses the ERISA implications of premium refunds (i.e., whether they are or are not "plan assets"). Most of these references have popped up in the context of the demutualization discussions of a couple of years ago. I have hunted high and low for a copy of this memorandum but have come up with zip so far. If anyone has a copy that they could send me, I would be eternally grateful.
smm Posted November 26, 2003 Posted November 26, 2003 Have you tried to locate her on the internet and see if she has a copy?
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