Surety bonds question; who has to get covered?

[Guest Enda80]

I looked over some issues related to Erisa 412(a)(1), Dol. Reg 2580.412-2, 412(a)(3), DOL Advisory Opinion 2004-07A (July 1, 2004), DOL Reg 2580 412-27-30, 2580.412-31-32, DOL Advisory Opinion 2004-07A, DOL 2580.412-2.

Anyway, my main question has to do with who has to get covered by a bond. Just employees? What about the people at the asset management company, in a hypothetical situation? Or since the asset management companies probably already have their employees bonded, is it not an issue for the employer supporting the plan?

[Locust]

The concept is that anyone who is in the position to embezzle the money has to be bonded. So trustees, a committee that authorizes payment, or an investment person who can actually direct investments would have to be bonded.

[Guest Enda80]

Hypothetical situation; say there is only one employee for the corporation or company (the owner himself or herself); does the owner still have to get a bond for the plan, even though there exist no other employees?

There are some small businesses which have only an owner who then farms out incidental duties to various companie.

[Mike Preston]

Hypothetical situation; say there is only one employee for the corporation or company (the owner himself or herself); does the owner still have to get a bond for the plan, even though there exist no other employees?

There are some small businesses which have only an owner who then farms out incidental duties to various companie.

As to the first paragraph, the answer is no. A plan that covers only the owner is not an ERISA plan. As such, no ERISA bond is required.

I don't kow how the second paragraph impacts the first. Could you expound?