The Wild Wild West of the 1970’s and 80’s
As those who were around back then will attest, the 1980s were a fun time be alive, especially in California. It was dubbed the “me decade”. Business was booming; the California Dream was thriving; and in Newport Beach, where I was living at the time, it seemed as if every other car was a Porsche, Mercedes, BMW or Jaguar. The popular slogan was “Go for it.” There was the feeling that anything was possible. Nothing was beyond your reach. You were limited only by your imagination and creativity. It was also often criticized as a decade of greed and excess. It was in this environment that the Multiple Employer Trust (MET) kicked into overdrive. This is an area of ERISA steeped in a complicated legal history. For those who want to do a deep dive into the subject, Edward A. Scallet, a fellow Washington Law University alum, wrote an excellent law review article about it back in 1983.  I wouldn’t dare to touch the subject, had it not been for the fact that I lived it for the year and a half after law school that I spent working for an MET administrator.
Before the insurance industry moved in for the kill, ERISA’s primary application in the health insurance market was through certain self-funded plans. These were generally provided by large employers or unions, who elected to “self-insure” their own health plans, as opposed to purchasing group insurance from an insurance company. Such self-funded plans were perfectly legitimate. Usually, the Plan Sponsor would hire a Third Party Administrator (TPA) to handle the day-to-day operations, such as claims management. However, the concept of the self-funded plan was taken to new heights by the emergence and proliferation of a unique and novel creature, the Multiple Employer Trust (MET). These captured a large segment of the group health insurance market in the late 1970s and early 1980s.
The MET was used as a device to allow employers to theoretically band together for the purpose of purchasing insurance or joining a self-funded plan. The insured METs were composed of small and medium sized employers, who were too small to qualify for group rates on their own. Therefore, they would join together to form a fictitious “trust”, through which premiums were paid and insurance purchased on behalf of their MET “group”. It was a way to create a large pool for the purpose of risk-sharing. Some federal circuits tolerated them; others did not. 
But a very different animal popped up at about the same time, mostly in California, the uninsured self-funded MET. These were also comprised of smaller employers, who lacked the resources to self-fund their own health plans and who were likewise finding it increasingly difficult to afford the skyrocketing premiums charged by the larger group health insurance companies. The self-funded METs were large group health plans, also administered by TPAs, except the TPAs were not hired by the employers (except perhaps on paper). The TPAs actually sold the plans to employers.
The uninsured METs looked almost like insurance plans and the TPAs, who administered them basically did everything that an insurance company might do. They employed a network of agents, who were eager to sell the plans, because the TPAs were extremely generous with commissions, paying substantially in excess of what the traditional insurance companies were paying. The MET plans offered a multitude of benefits, which were sold at prices substantially below what traditional insurance companies were charging at the time. As result of all these factors, they grew dramatically in the late 1970s and early 80s. Although many negative things can be said of them, they were in many ways both ingenious and revolutionary in design.
To understand how this was pulled off, you have to know a little bit about the Law of Trusts, which is boring but I’m going to keep it quick and simple. The proprietors of the METs and their attorneys were an innovative bunch of folks. Using ERISA as their primary vehicle, the METs took two of the most revered legal concepts of our civil law -- that of a “Trust” and that of “fiduciary duty” – and they annihilated them. In order to appreciate how they did it, it helps if you first understand what a “Trust” is supposed to be under our civil law. A “Trust” is a legal abstraction. Under basic Trust Law, it is established by a “Grantor” or “Settlor”, who places certain assets into a Trust, where they are held for the benefit of others (the “beneficiaries” of the Trust). The assets are then overseen by an independent “Trustee”, who manages the assets for the benefit of the intended beneficiaries. The Trustee is held by law to fiduciary standards of conduct in discharging its responsibilities. The concept of “fiduciary duty” is also a legal abstraction. It’s is the highest duty that can be imposed by our civil law.
The ERISA statute imposes fiduciary responsibility on any person who exercises discretionary authority or discretionary control respecting the management or disposition of plan assets or has any discretionary authority regarding the administration of the plan. A “prudent person” standard is imposed on ERISA fiduciaries.  A fiduciary is also under a duty of loyalty and care to the beneficiaries of the plan. Under ERISA: (1) A fiduciary must discharge his or her duties solely in the interest of plan participants and beneficiaries and for the exclusive purpose of providing plan benefits to them; (2) A fiduciary must act with care, skill prudence and diligence; and (3) a fiduciary may not act in any capacity involving the plan, on behalf of a party whose interests are adverse to the interests of the plan, its participants, or its beneficiaries. All of this sounds good but the words ring hollow in the real world of ERISA. 
The METs took these legal concepts and turned them on their ear. For example, if we apply basic Trust Law concepts to those entities known as “Multiple- Employer Trusts”, then the “settlors” or “grantors” of these METs would necessarily have to be the employers, since it was they, who established the METs for the benefit of their employees. Right? Hardly. The METs were not formed by groups of small business employers, banding together to create some kind of “self-insured” pool, although that indeed was the fiction. The METs were set up by the companies who administered them -- the TPAs. 
Instead of having independent trustees overseeing the assets, the named trustees of an MET might be the wives or secretaries of the proprietors of the TPA. Sometimes the TPA’s bank, would agree to serve as Trustee, so long as the TPA maintained its multi-million dollar claims and trust accounts with the bank (an ever so slight conflict of interest). The thing to know about the trustees of an MET is that they did absolutely nothing. They played no role whatsoever in decision making or oversight. They were mere figureheads and they served in their capacity as trustee in name only.
The drama begins, with the TPA issuing a “Master Plan Document” to the Trust. Each employer, who purchased the plan would sign a “participation agreement”, conveniently provided by the TPA, by which the employer unit (i.e. the employees and their dependents) joined the MET and agreed to pay the stated monthly premium. The TPA would then issue benefits booklets (known under ERISA as “Summary Plan Descriptions”) to the employee / “plan participants”, which were supposed to essentially summarize the plan benefits set forth in the “Master Plan Document”. These benefit booklets were very much like the “Certificate Booklets”, which up to that point in time were commonly issued to individual insureds under various group insurance plans. In many instances the TPAs just copied the form of old Certificate Booklets of various insurance companies.
Frequently, the employees paid all or part of the monthly premium through payroll deductions. To be more precise, the various employer units did not actually pay “premiums” to the MET, because by definition, “premiums” are “the consideration paid for a contract of insurance”.  Instead, they paid “contributions” to the “self-funded Trust”, which for all practical purposes were the same thing as premiums. In theory, these contributions were deposited by the TPA into a “Trust account”. Funds were then transferred periodically to a “claims account”, upon which checks were written to cover the outstanding claims. The Trust account was nothing more than an interest-bearing market-rate account.
After setting up the bogus Trust, the TPA would put together a benefit Plan; market it to various employer groups and then under a separate contract, it would charge the MET a fee for claims administration services. A TPA would typically charge an administrative fee of 10-15% of the gross contributions and would also pick up sizable chunks of interest on the funds held in the Trust account. (Some of you older folks may remember that during this time period money-market interest rates were well into the double digits.)
All of this occurred in what was at that time a complete regulatory vacuum. It was in fact the Wild, Wild West. No one involved had a clear handle on who could do what or exactly what would happen next, not state regulators, not the U.S. Department of Labor (DOL) and certainly not the METs. But on the legal end, it left an enormous amount of room for creativity, at least for a while. The regulatory uncertainty of this new frontier invited some of the very first ERISA pre-emption arguments, hatched by MET attorneys in their efforts to hold state regulators at bay. They advanced the argument in federal court that the federal ERISA law pre-empted all state insurance laws, as they related to the self-funded METs. Although states do retain the jurisdiction to regulate the business of insurance, even under ERISA, the METs argued that they were not engaged in the business of “insurance”. They were ERISA “trusts”. It was further argued that only the DOL had regulatory jurisdiction over the METs (ERISA was enacted as part of the U.S. Labor Code.) The DOL, however, did not have the means or the inclination or even the skill set to regulate METs, as the MET attorneys were well aware.
Although ERISA does contain a “pre-emption” clause, it was never intended to regulate all employer-sponsored benefit plans and no one ever dreamt at the time the law was enacted that ERISA pre-emption would turn out to be what it ultimately became. However, when the federal courts started buying many of the ERISA pre-emption arguments, a new species of federal common law was born and many of those arguments were initially nothing more than ploys to keep state regulators off the backs of the METs. 
In California, the Departments of Insurance and Corporations (the DOI and DOC) were the state regulatory players in this high stakes drama and they were not about to just slip away gently into that good night. The DOI had jurisdiction over insurance companies of course and the DOC had jurisdiction over “health plans”, under what is known as the Knox-Keene Act.  As the METs proliferated in California, the DOI and DOC grew increasingly nervous. The METs presented an oversight challenge, the likes of which no one had ever encountered before. Although they were huge plans, “insuring” tens of thousands of people, they were not licensed or directly regulated by anyone. They were also of dubious solvency, since not a single one of them complied with even the most basic capital and surplus requirements of state insurance law. But, as they signed up more and more new participants, they appeared to flourish financially. In a sense, they were like giant Ponzi schemes. Over time, under-funded and under-reserved, the METs found themselves simply using new money to pay off past claims liabilities, “robbing Peter to pay Paul”. But, as long as they kept growing, they were able to maintain the illusion of solvency. But attempts to regulate them initially resulted in a high-stakes game of cat and mouse.
“Stop-Loss” Coverage: What It Is and How It Works
The TPAs would receive the contributions from participating employers and use that money to pay claims up to a certain amount; pay themselves administrative costs; perhaps under a separate contract pay an affiliated managed care company to handle “case management” services for the Plan, such as pre-certifications for proposed treatments, and then sometimes they would purchase a stop-loss policy to cover a percentage of the claims liability.
In gambling parlance, stop-loss insurance would be known as “the laying off of a bet”. Rather than have the MET assume 100% of the risk for the health plans sold, the TPA would purchase stop-loss coverage to indemnify the MET for a part of that risk, thus protecting the solvency of the Trust itself. Sounds prudent enough on the surface. But in the strange world of ERISA, things are seldom what they seem. The TPAs devised new (and sometimes legally suspect) ways to use such coverage.
A stop-loss policy itself is a simple document, consisting of perhaps a page or two, to which a copy of the “Plan Document” is attached. It may incorporate the “insuring” provisions of the Plan so that it parallels those of the Plan. The most important provisions of a stop-loss policy are those specifying the carrier’s liability limit, both “specific” and “aggregate”. Viewed in reverse, these provisions effectively define the self-funded plan’s risk exposure or “retention”. Specific stop-loss coverage reimburses the MET for any claim over a certain amount, (e.g. $5,000). Aggregate stop-loss coverage reimburses the MET for any amount over and above the Plan’s retention for all claims in a given year (e.g. $1,000,000).
In some instances, a TPA would buy this coverage from its own captive or affiliate, usually domiciled in another state with lower capital and surplus requirements. In those cases, the TPAs, who was already taking 10% to 15% of the gross contributions for administrative fees and playing the float on the money held by the MET to boot, could boost revenues further, by arranging for the provision of stop-loss coverage by a company it owned or controlled. This allowed even more funds to be diverted to the captive or affiliate in the form of premiums paid for the stop-loss coverage.
Frequently, stop-loss policies were combined with the self-funded plan, in such a way so that the operative effect was almost the same as if a health insurance company had issued a traditional group insurance policy in the first place -- but with an interesting twist -- there would be no direct liability of the actual insuring company to the “insured” employees. That’s because a stop-loss policy is a unique species of insurance policy in that it is regarded as a private contract between the carrier and the insured entity. In the MET scenario, it has only one insured, the MET. The plan participant has no standing to sue, no right of recovery against the stop-loss carrier and may not even know about the existence of the stop-loss arrangement.
Under some unusual and convoluted arrangements, the stop-loss carrier might agree to reimburse the self-funded MET for as much as 100% of the losses incurred. In other words, all risk was passed through to the stop loss carrier. In that situation, the MET was nothing more than a vehicle for the purchase of stop-loss coverage and the upstreaming of premium dollars to the TPA’s captive stop-loss carrier. This was a shell game involving many millions of dollars. The scheme was a classic example of an ERISA “conflict of interest”
Why go to this much trouble, when you could just buy a group health policy from a traditional insurance company in the first place? For several reasons. First of all, no matter how large the MET “group” might be, it could not negotiate any kind of group premium rate that would be remotely competitive with what the METs were charging. Secondly, by breaking down the various insurance-related services into: claims administration, managed care, stop-loss, etc., a separate company, affiliate or subsidiary could bill for each service rendered. Not one of those entities had any contractual obligation to the plan participant; therefore, they theoretically had no legal liability, no matter what they might do in relation to the Plan. Thirdly, except as imposed by law, those entities had little or no fiduciary responsibility to the Plan or the plan participants. Finally, as far as the stop-loss carrier was concerned, it could jump “off the risk” any time it wanted, incurring no liability for any unreported claims.
In most cases, claims administration and managed care agreements, as well as stop-loss policies were careful to disclaim fiduciary responsibility under ERISA. In some instances, the stop-loss carrier may have actually controlled the administration of the plan from start to finish; nevertheless, through utter contrivance, it would try to side-step legal liability for its actions. This created a problem, however, because somebody had to be the Plan fiduciary by law. Under ERISA any entity exercising discretionary authority over management of the plan or disposition of its assets is a deemed fiduciary, whether they technically disclaim it or not.  The problem was who was going to enforce it? Since regulatory entities were left dumbfounded, the only resort was to the courts. And the development of ERISA law took a very long time to evolve.
The Actual Coverage: Now You See It - Now You Don’t
An insurance company, writing traditional group health insurance, must correctly anticipate its claims liability and adjust premiums accordingly. If the insurer is careless, incompetent or just unlucky, it can sustain serious financial loss. That is why state insurance laws impose capital and surplus requirements on insurance companies so that in theory they can meet their financial obligations to policyholders. That includes certain continuing obligations, when a plan terminates. At that point, the insurer is still responsible for paying all “incurred but not reported” (IBNR) claims. This is also called the “run off", or “the tail". IBNR claims may extend out for months after the termination date of coverage. During this period, the insurance company will be on the hook financially for paying the “run off” claims, but it will receive no new premium dollars to offset that liability. Depending upon the extent to which the insurance company set aside “reserves” to cover the “run off", every new claim cuts deeper into the insurance company profits. The IBNR losses can be staggering if you’re talking about a large group or block of business.
But if all an insuring company does is provide indirect stop-loss coverage to a self-funded Plan, that coverage may be tailored to begin on a certain date and to end on a certain date. The policy may provide that the stop-loss carrier will not be responsible for any run off claims after a certain date. Furthermore, if it looks like the self-funded Plan is experiencing or is about to experience unexpected losses, the stop-loss carrier may give notice, terminate its contract abruptly and fade out of sight, after having picked up some nifty profits for the time period that it did provide coverage.
The “Front Company” Flimflam
Interestingly, even the METs themselves did not expect their proffered ERISA pre-emption analysis to fly for very long. In fact, for a while, the U.S. Department of Labor basically gave the “green light” to state regulators to go in and regulate them. This meant that state authorities could potentially terminate a self-funded MET on grounds it was operating as an unlicensed insurance or health plan. However, the TPAs certainly wanted to keep their METs going for as long as possible. These were huge administrative operations, with complex personnel requirements and substantial overhead investment. So that meant keeping the state watchdogs at bay for as long as possible. With the regulatory issue up in the air and with the METs facing the possibility of being shut down entirely by the state, the METs were certainly not about to put all their eggs in the ERISA pre-emption basket. In order to hedge their bets, the self-funded METs prepared to shift gears and adopt an entirely new strategy to fend off state regulators -- alas, the “front company” scheme was devised. Under this arrangement, the formerly “self-funded” MET could become fully “insured” overnight if necessary by the simple use of a “front company”. 
The words, “front company” have a Mafia-esq ring, but the concept was sophisticated and complex. It works like this. Everything is exactly the same as with the self-funded MET scenario described above, but with an added player – an actual insurance company posing as an insuring entity. Here’s an illustration: The TPA sets up its own “captive” or “affiliate” insurance company. We’ll call it the “XYZ Captive Insurance Company”. XYZ issues a stop-loss policy to the MET. The stop-loss policy provides for a “pass through” of 100% of the MET’s claims liability. In other words, the MET’s “retention” is zero.
Then, enter the “ABC Legitimate Insurance Company”, a California admitted insurance carrier, licensed to write group health insurance in California. The MET obtains a master “policy” from ABC. Actually, the policy is one written up by the MET attorneys so that it will be consistent with the plan that the MET is already offering to the public and ABC simply puts its name on the policy. ABC then either obtains reinsurance from (or through) XYZ, as well as an indemnity agreement by which XYZ agrees to indemnify ABC for any losses incurred by ABC as the result of its agreement to “front” for the MET. Thus, all losses are passed from the MET to ABC back to XYZ. Confused? That’s understandable. It was a complicated arrangement, with a lot of moving parts, any one of which could withdraw at any time, causing the entire house of cards to collapse. If ABC felt uncomfortable with XYZ’s financial ability to reimburse it, then in order to placate ABC, XYZ might agree to obtain a number of reinsurers, who would each take a percentage of XYZ’s total exposure, for a significant reinsurance premium.
ABC does not actually receive any premiums from the MET under this ruse, nor does it pay any claims. In theory, ABC assumes no risk at all but receives a substantial “fronting” fee from the MET, for basically renting the use of its name and license to the MET. In theory, XYZ and its reinsurers assume 100% of ABC’s risk. That’s the theory. In this scenario, if the whole thing collapses, the ABC and its reinsurers are theoretically left holding the bag. I say theoretically, because if the whole thing falls down, you can expect there to be a barrage of lawsuits. Also, you have to bear in mind that in this set-up, everyone is a scoundrel out to screw everyone else.
The purpose of the fronting arrangement is to: (A) satisfy state regulators that the plan is in fact “fully insured”, so as to placate the public. (You have to understand the regulators didn’t really give a shit and in fact it wouldn’t have been any great surprise to find any one of them on a golf course with any of the other players in this game.); (B) satisfy insureds that their claims will be paid by giving them the illusion of legitimate insurance coverage; and (C) allow a large part of the funds, ostensibly held to pay claims to be converted into revenue for the “captive” or “affiliate” stop loss carrier. But the inherent problem with it is there are too many palms to grease. It’s extremely expensive. And that expense can only be managed in one of two ways, the MET either raises its “contribution” amounts paid by its covered members to cover the added cost or it does its best to continue to grow and expand to keep new dollars coming in the door to cover past liabilities. Neither the regulators nor the insureds would necessarily know about the behind the scenes fronting deal.
It doesn’t exactly take a genius to figure out that this was a dangerous game for a legitimate insurance company to play. Because if an MET did go bankrupt, neither the insureds, nor the state regulators, nor the courts would care about the fronting deal. In my example, they would all look to the ABC Legitimate Insurance Company to make good on any claims. And if a U.S. Bankruptcy Trustee is appointed to liquidate the remaining assets, you can also expect that the Trustee will look directly to the front company for payment.  Therefore, on the surface, it would seem that any front company arrangement would be asinine and that only the stupidest insurance companies would agree to it. But some did. Why? Because as I said, everyone involved is a scoundrel. The front companies had a totally different agenda. They weren’t the least bit interested in solving the legal or regulatory problems of the METs. Motivated by their own greed, they were playing a different game called “hit and run”, in which they would never stay on any given risk for very long. The objective of the front company was to go in quickly; front for the MET for a short period of time (e.g. 90 days); pick up a few million dollars in fronting fees; and then run like hell, putting as much distance between themselves and the MET as possible. A smart front company would do an audit of the MET before agreeing to the deal to make sure that things looked OK for the time being (i.e. that it had enough money coming in to pay claims for at least the limited period of the fronting arrangement). Beyond that, the front company could care less. In other words, the front company wanted to get in on the Ponzi scheme well before the bubble would burst, pick up some quick cash and get out clean.
Of course, when a front company jumped off the risk, the MET was left “bare” (without insurance) and once again vulnerable to state regulators, who were frequently parked outside the door of the TPA ready to pounce. Not to worry, because right up until the time when it was almost ready to go pop, another, perhaps more dubious, insurance company could be found that was willing to front for the MET for a little while longer. However, with each successive deal, the fees would go up and the quality and “Best Rating” of the company would go down, until ultimately it was some outfit no one had ever heard of. Because of the exorbitant amounts charged by the front companies near the end of the ride, these arrangements had the effect of taking a fiscally precarious self-funded MET and pushing it even closer to the brink of insolvency. Eventually, the financial bubble burst and the MET would be left high and dry, uninsured, financially drained and insolvent, with millions of dollars of claims left unpaid. But before making their exit, all of the characters involved in this production picked up enormous profits on the backs of unsuspecting insureds, who had paid their premiums religiously, only to be left holding the bag for unpaid health care claims. Whenever a self-funded MET went “belly-up”, it was national news, sending shock waves throughout the country. Horror stories would abound. Patients in need of heart by-pass surgery or dialysis were suddenly left uninsured and unable to get the medical treatment they desperately needed. Other helpless insureds, who had incurred enormous medical expenses, were left to face personal responsibility for the unpaid bills and possible bankruptcy.
From the TPA’s perspective, however, it really didn’t matter if the MET was financially sound or not. As long as the money was coming in (and we’re talking about tens of millions of dollars back when that was a lot of cash), the TPAs were doing quite well. They were getting their cut for administrative fees; plus the float on the money they were holding; plus any money they might be making on the premiums if they were using their own captive or affiliate stop-loss carrier. Given the amount of money that could be made in the short term, who cared if the Trust eventually became insolvent in the long term. Even if it did, the TPA would just go down the road and start another one. As I said, at the time, it was the Wild, Wild West. But eventually, the day of reckoning came for each one of the self-funded METs.
ERISA was enacted in part to address pension plan mismanagement, such as had occurred with the Teamsters Central States Pension Fund.  In what is perhaps an ironic twist, the final chapter of the California MET saga came in November 1986, when the proprietors of one MET, Far West Administrators Inc., along with the health plan’s administrator, were convicted of embezzling $1.5 million from the Long Beach Teamsters Union health plan fund. According a Los Angeles Times article, “In all, six defendants were charged with embezzling the money from the trust between 1979 and 1981. Their actions left thousands of unpaid medical bills and forced the health plan into receivership, according to prosecutors.” 
Today the regulatory landscape has changed radically from what it was back then. The law does allow for a species of MET, as well as a Multiple Employer Welfare Arrangement (MEWA), which are occasionally found today. But they are fundamentally different than their front-runners discussed above. The type of plan described here has practically disappeared. Infamous for their poor underwriting standards, the large unregulated METs went bankrupt in the early 1980s, leaving tens of thousands of California residents without insurance and many millions of dollars in unpaid claims. However, they left an indelible mark on the health care and insurance industries. The METs pioneered many of the managed care concepts that we take for granted today, including “duel-option” plans (which were the forerunners of “preferred provider organizations” (PPOs) and “exclusive provider organizations” (EPOs). The METs were among the first to use ERISA and its pre-emption clause to shield insurance operations that would not be tolerated today.
Although the early METs blazed the trail, it was the conservative, insurance industry giants, following in their footsteps, who eventually took both managed care and ERISA pre-emption to greater extremes over the following decades. All of the major health and long-term disability insurance companies eventually took notice of the ERISA pre-emption arguments and the protection that ERISA could afford them from state consumer laws, particularly “bad faith” lawsuits and punitive damage exposure. Although it was never the intent of Congress, before the major insurance companies would be finished, ERISA would (primarily as the result of federal judicial decisions) dominate the entire field of employer-sponsored health, disability, life insurance and other employee benefit plans.
 Edward A. Scallet, The Regulation of Multiple Employer Trusts: Past, Present & Future, 61 Wash. U. L. Q. 359 (1983). Available at:
 See, e.g., The Taggart Corporation v. Life and Health Benefits Administration, Inc., 617 F.2d 1208 (5th Cir., 1980).
 29 USC Section 1104(a)(1)(b).
 29 USC Section 1104(a)(1).
 See Insurance & Prepaid Benefits Trust v. Marshall, 90 F.R.D. 703 (C.D. Cal. 1981).
 See Scallet, at 17-21.
 The Knox-Keene Health Care Service Plan Act of 1975, California Health & Safety Code, section 1340 et seq.
 29 U.S.C. §1002 (21)(A).
 Evanston Ins. Co. v. Security Assur. Co., 715 F. Supp. 1405, 1407, fn 3 (ND, Ill., 1989).
 “Long-Bankrupt Health Insurer’s Claims Settled”, Los Angeles Times, by Bruce Keppel, Times Staff Writer.
 See, e.g., "Teamster’s Central States Pension Fund Reform and ERISA Enforcement Remedies”, Hearing Before The Subcommittee On Oversight Of The Committee On Ways And Means House Of Representatives Ninety-Seventh Congress Second Session. July 26, 1982U.S. Government Printing Office’ Washington 1982, page 217; And see, “Oversight of Labor Department Investigation of Teamsters Central States Pension Fund”, Hearings Before the Permanent Subcommittee on Investigations of the Committee on Governmental Affairs, United States Senate, Ninety-Sixth Congress Second Session, August 25 and 26 And September 29 and 30, 1980, U.S. Government Printing Office’ Washington 1982, pages 188, 287-288.
 “2 Convicted of Embezzling Union Funds: $1.5 Million Was Stolen From Teamster Local's Health Plan” , Jane Applegate, Staff Writer, Los Angeles Times, November 13, 1986.
The Legacy of The Multiple Employer Trusts
By: Michael A. McKuin
ERISA Disability Lawyer