Facts: Bank holding company has four separate banks as subsidiaries in four locations in two states. The insurance benefit plans are all fully insured.

Each bank and the holding company offer employer sponsored health, LTD, life, and dental plans to employees. Currently, each bank and the holding company has offered different plans to it's employees.

The holding company has been told ERISA requires all banks under the holding company to offer the same benefit plans.

Can anyone give me verification or refute this advice and a place to go for back up?

Thanks for any information.

There is no ERISA rule mandating similar coverage for control group members for welfare plans.

There are a few nondiscrimination rules under Internal Revenue Code sections 105 and 125 that might apply, though. (These pertain to self-insured medical expense reimbursement plans and to "cafeteria" plans.)

[This message has been edited by Dave Baker (edited 03-08-2000).]

I 2nd thhat opinion.
Sounds like there may be some confusion with the original opinion commig from someone more familar with retirement plan rules.

Health and welfare benefits often differ substantially in differing geographic regions or based on histories of the different units.

Certainly economies can be realized by consolidating vendors and common designs facilitate employee movement among divisions.

But barring designs which grossly favor high paids you should be OK.

Be careful in the Section 125 dependent care and Medical spending account areas.

------------------
jlcowden

That's what I thought and thank you for responding.