"[T]he IFBF was established for purposes other than the provision of insurance, participation in the Consortium and the Plan is limited to employer members of the IFBF, and the Participating Employers in the Consortium and the Plan have a long-standing history of collaboration through their IFBF membership ... Therefore, the Department would view these Participating Employers as having a commonality of interest and a genuine organizational relationship unrelated to the Plan through their IFBF membership.... [It] is the Department's view that the Participating Employers would, at least in form, constitute a bona fide group or association of employers for purposes of ERISA section 3(5), and the Plan, at least in form, would constitute an employee welfare benefit plan for purposes of Title I of ERISA."  MORE >>