Delaye v. Agripac (9th Cir.) held that monthly payments over a two-year period did not require which ERISA condition?

Delaye v. Agripac (9th Cir.) held that monthly payments over a two-year period did not require which ERISA condition?

• A. Ongoing administrative scheme
• B. Immediate vesting
• C. Adherence to COBRA
• D. Fiduciary duty

Answer: (A)

The key idea is whether ERISA kicks in based on the existence of an ongoing administrative framework to manage the benefits. In Delaye v. Agripac, the court looked at a arrangement where payments were made monthly for a fixed two-year period and concluded that this did not create an ongoing administrative scheme. Since ERISA coverage hinges on having ongoing administration of a plan, a finite, two-year payout plan isn’t treated as an ERISA plan requiring ongoing administration. That’s why the condition that isn’t required in this context is an ongoing administrative scheme. For clarity, vesting, COBRA adherence, and fiduciary duties relate to other aspects of ERISA and benefit design, but the specific point in this case is about whether there’s an ongoing administration to justify ERISA’s applicability.

The key idea is whether ERISA kicks in based on the existence of an ongoing administrative framework to manage the benefits. In Delaye v. Agripac, the court looked at a arrangement where payments were made monthly for a fixed two-year period and concluded that this did not create an ongoing administrative scheme. Since ERISA coverage hinges on having ongoing administration of a plan, a finite, two-year payout plan isn’t treated as an ERISA plan requiring ongoing administration. That’s why the condition that isn’t required in this context is an ongoing administrative scheme.

For clarity, vesting, COBRA adherence, and fiduciary duties relate to other aspects of ERISA and benefit design, but the specific point in this case is about whether there’s an ongoing administration to justify ERISA’s applicability.