A multiemployer plan is an employee benefit plan maintained pursuant to a collective bargaining agreement between more than one employer, usually within the same or related industries, and a labor union.
The FAQs describe arrangements in which a multiemployer plan leases office space or classroom space to or from a sponsoring union or other party who has a relationship to the plan and the prohibited transaction rules that are violated by those arrangements. Also addressed are the administrative and statutory exemptions that may apply with an analysis of the specific prohibited transaction provisions that are covered by each exemption.
The FAQs also describe the consequences to a plan fiduciary if a leasing arrangement is prohibited but does not qualify for an exemption.
The questions and answers are available at http://www.dol.gov/ebsa.
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