so, would we have an issue?

 -----Original Message-----
From: 	Barrow, Cynthia  
Sent:	Tuesday, July 24, 2001 9:46 AM
To:	Cash, Michelle
Subject:	RE: Confidential Communication to my Attorney

I think the issue is that if they only have one client then they could be considered employees from a 'discrim/coverage' standpoint.  The issue is probably not in the area of insured plans but the qualified plans.  The 410(b) is our adequate coverage test for the pension plan.


Cb

 -----Original Message-----
From: 	Cash, Michelle  
Sent:	Tuesday, July 24, 2001 9:39 AM
To:	Barrow, Cynthia
Subject:	RE: Confidential Communication to my Attorney

who knows.  I can't imagine that a customer would somehow owe insurance to the provider's employees.  Michelle

 -----Original Message-----
From: 	Barrow, Cynthia  
Sent:	Tuesday, July 24, 2001 9:37 AM
To:	Cash, Michelle
Subject:	RE: Confidential Communication to my Attorney

God I hope not!  However, we do include a portion of leased employees in our 410(b) tests for 'insurance'.  I'd like to know who he talked with.  

 -----Original Message-----
From: 	Cash, Michelle  
Sent:	Tuesday, July 24, 2001 9:18 AM
To:	Barrow, Cynthia
Subject:	FW: Confidential Communication to my Attorney

Cynthia, do you know anything about this type of requirement?  Michelle

 -----Original Message-----
From: 	"Hoyt H. Thomas" <hhth@earthlink.net>@ENRON [mailto:IMCEANOTES-+22Hoyt+20H+2E+20Thomas+22+20+3Chhth+40earthlink+2Enet+3E+40ENRON@ENRON.com] 
Sent:	Tuesday, July 24, 2001 9:16 AM
To:	Cash, Michelle
Cc:	Booth, Khymberly; Tholan, Scott
Subject:	Confidential Communication to my Attorney

Michelle, I was presented with some interesting information yesterday
and I wanted to run it by you . . . I was not told this by an ERISA
attorney but it was a person who works with Benefits frequently.  The
person told me that, if a company only had one customer, the company's
employees had to be included in the control group of the customer for
discrimination testing purposes on the benefits plans.  It sounded a
little iffy to me . . . could you verify?  Thanks.

Hoyt

--
Hoyt H. Thomas
713.668.3122
713.201.1622 Mobile