"[C]hurch affiliates relying on the principal-purpose organization basis to classify their plans as church plans should review their plan governance structure to ensure that they can show that their plans are maintained by an organization that is controlled by or associated with a church and that has the principal purpose of overseeing employee benefit plans of churches or church affiliates. Control of a principal-purpose organization by a church can be shown by a church's control over the appointment of the organization's manager or majority of board members. Association with a church is a subjective analysis that considers whether the organization shares common religious bonds and conventions with that church." [Advocate Health Care Network v. Stapleton, No. 16-74 (U.S. June 3, 2017)]

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