"Because multiple employer plans provide many of the same efficiencies as pre-approved plans, multiple employer plans should be eligible for determination letters.... [P]rivate letter rulings (PLRs) should be issued with respect to certain plan qualification issues.... [In many] cases, such as large mergers and acquisitions, there is a real need for the greater reliance achieved through the determination process. Legally, an opinion letter does not provide the same level of reliance as a determination letter."  MORE >>