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Does your company provide any type of benefit to the family members of deceased employees? A DOL opinion letter issued recently is a good reminder that the provision of any type of benefit upon the death of an employee may result in the creation of an employee welfare benefit plan unless the benefit is viewed as a "remembrance fund" under DOL regulations. Generally, prior to this ruling, cash amounts paid at death of less than $100 had been deemed a "remembrance fund," and cash amounts paid at death of $1,000 or more had not been deemed a "remembrance fund" for the exception to apply. This new ruling actually allows a cash amount of $250 to be classified as a "remembrance fund" so that the exception will apply.

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