"[F]or a voluntary plan arrangement to fall within the safe harbor, the employer's role is strictly limited by DOL regulations. Specifically: [1] [The employer] cannot require or coerce employees to participate.... [2] The employer cannot make any contributions to the plan.... [3] The employer's functions are limited ... [4] Employers cannot endorse the plan.... [5] Employers may not receive any consideration from the insurer. "  MORE >>