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Union bond purchases as current compensation
Summary DOL found that bonds a union bought monthly for its secretary, which immediately became her property, were current compensation rather than an ERISA pension plan. The conclusion depends on the employee’s immediate ownership and ability to use the bonds; no ERISA reports were required for those purchases.
Document
Federal opinion letter
Agency
U.S. Department of Labor, Employee Benefits Security Administration (EBSA)
Document number
P/OPINION 75-09
Date issued
June 24, 1975
Status
Unknown
EBSA's index does not mark withdrawn or superseded opinions; still posted on dol.gov as of 2026-10-26.
Status last verified October 26, 2026
Topics
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About this page: The full text below is the official document from U.S. Department of Labor, Employee Benefits Security Administration (EBSA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
P/OPINION 75-09
3(2)
June 24, 1975
Dear :
This will confirm your telephone conversation with
of my staff concerning your inquiry about
the bond purchase plan your union has for its office
secretary. You explained in your earlier letter that
the union purchases a bond for her each month which
immediately becomes her property. Under these
circumstances we do not think you maintain a pension
plan within the meaning of the Employee Retirement
Income Security Act of 1974 (ERISA). Rather, you
are currently paying compensation in a bond form which your
employee may retain for her retirement, but which she
may use almost immediately, and on which we assume she is
currently taxable. No reports are required on the bond
purchases of this type under ERISA.
Sincerely,
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