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Proposed New Enforcement Procedures and Reporting for MEWAs (PDF)
Eversheds Sutherland via Lexology; registration required 
[Guidance Overview] Dec. 8, 2011 While the objective of these rules is to police fraudulent or otherwise abusive arrangements in the marketplace, as discussed above, a bona fide welfare plan covering employees of multiple members of a business enterprise sometimes can also be a MEWA, depending on the ownership, control and other structural relationships in that enterprise. The consequences of the proposed reporting rules in those circumstances should be carefully considered[.] MORE >> |
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