Unfunded Plan Rules-Bond

[Guest Pecos]

Under the Bond Rules, there is a requirement to have a bond if "any benefits under the plan are provided or underwritten by an insurance carrier or service or other organization"

For a self-funded health plan with stop loss (reinsurance) insurance for aggregate or individual maximums, does the above statement mean that this type of plan would need to have a bond? The benefit funds are mixed with the general assets of the employer (not separated by bank accounts, no trust, etc). The employees do have medical premiums deducted from their paychecks and those funds, I think, are commingled with general assets.