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| Advisory Opinion 2004-10A on the May Department Stores Co. Vacation Pay Program U.S. Department of Labor [DOL]  [Official Guidance] Jan. 11, 2005 Excerpt: This is in response to your request on behalf of The May Department Stores Company (May Company) for an advisory opinion under Title I of the Employee Retirement Income Security Act of 1974, as amended (ERISA). Specifically, you ask whether May Company's vacation pay program (Program) is a 'payroll practice' within the meaning of Department of Labor (Department) regulation at 29 C.F.R. § 2510.3-1(b)(3) and, therefore, not an employee welfare benefit plan within the meaning of[.] |
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