| 81-31 |
| September 22, 1981 |
| REFERENCE: |
| 4021(b)(2) Plans Covered. Government Plans |
| OPINION: |
| This is in response to your request for a reconsideration of the determination that the above pension plan (the "Plan") is |
| covered by Title IV of the Employee Retirement Income Security Act of 1974 ("ERISA"). Upon reconsidering the matter |
| with the additional information you submitted, we have concluded that the Plan is excluded from coverage under Title IV of |
| Section 4021(b)(2) of ERISA, 29 U.S.C. § 1321(b)(2), excludes from Title IV coverage any plan "established and |
| maintained for its employees by the Government of the United States, by the government of any State or political |
| subdivision thereof, or by any agency or instrumentality of any of the foregoing . . . ." |
| As you have represented the facts, the * * * is a "public trust" with the City of * * * Oklahoma as the exclusive |
| beneficiary, created pursuant to Sections 176 to 180 of Title 60, Oklahoma Statutes. These statutes provide for the |
| creation of trusts with municipalities as the beneficiaries for the purpose of furthering any authorized public function. Such |
| a trust may be created only by the express approval of two-thirds (2/3) of the membership of the governing body of the |
| beneficiary. 60 O.S. § 176(a). Public trusts may be terminated by agreement of the trustees and the governing body of |
| the beneficiaries, with the approval of the Governor. 60 O.S. § 180. Public trusts are required to file a monthly report of |
| all expenditures of bond proceeds with the governing board of the beneficiary. Public trusts must file with the State |
| Auditor and Inspector an annual audit certified by the unqualified opinion of a certified public accountant, certified |
| Public trusts are not granted taxing authority and the beneficiary municipality is not responsible for the obligations of the |
| public trust (60 O.S. § 177); a public trust, however, cannot create an indebtedness or obligation without approval by a |
| two-thirds (2/3) vote of the governing body of the municipality. 60 O.S. § 176(d). Before a public trust may issue bonds, |
| notes, or other evidence of indebtedness, it must file with the Secretary of State, a preliminary copy of the official |
| statement, prospectus or other offering document pertaining to the issuance, unless statutory exceptions apply. 60 O.S. |
| § 178.2. Bonds issued by a public trust as well as contracts for construction, labor, equipment, material, or repairs, must |
| be awarded to the lowest and best bidder based upon open competitive bidding unless statutory exceptions apply. 60 O.S. |
| Although the Oklahoma statutes governing public trusts permit a significant amount of autonomy in the management of |
| trust assets and the selection of trustees, the State of Oklahoma treats public trusts as its political subdivisions or |
| agencies of such political subdivisions. Section 179, Title 60, Oklahoma Statutes, states that trustees of a public trust are |
| an agency of the State and the regularly constituted authority of the beneficiary for the performance of the functions of |
| the trust. Accordingly, trustees of a public trust are required to take the oath of office required of an elected officer. 60 |
| O.S. § 178(a). Additionally, public trusts must file with the Secretary of State a list of all conflicts of interest which its |
| Meetings of trustees of all ublic trusts are open to the public to the same extent as is required by law for public boards and |
| commissions. 60 O.S. § 178(d). The "Open Meeting Act" of Oklahoma at 25 O.S. § 304(1) defines the governing body |
| of a public trust as a public body. Records of a public trust and minutes of all public trust meetings are open to |
| inspection by the general public as are records of meetings of governmental agencies. 60 O.S. § 178(d); Op. Att. Gen. |
| No. 76-373 (February 4, 1977.) |
| In 1978, Oklahoma adopted the Political Subdivision Tort Claims Act. This Act defined a political subdivision as, among |
| other things, "a public trust where a city, town, school district or county is a beneficiary . . . ." 51 O.S. § 152(6). In 1979, |
| the Oklahoma Legislature amended the statutes governing interest on judgments. The amended statute classifies a public |
| trust of which the State of Oklahoma or a political subdivision thereof is a beneficiary as a political subdivision of the |
| State of oklahoma, resulting in a lesser rate of interest on judgments against such entities. 12 O.S. § 727. |
| Oklahoma's Workers' Compensation laws address the coverage of public trusts under the section titled, "Coverage for |
| certain public employees", which provides identical treatment for public trusts, counties, cities, and the State. 85 O.S. § |
| 2b. Likewise, the unemployment compensation laws of Oklahoma treat public trusts as political subdivisions of the State. |
| The Supreme Court of Oklahoma in the case of County Commissioners of Oklahoma County v. Warram, 285 P.2d 1034 |
| (Okl. 1955), held that since gifts to and income or profits derived by the state, or any county, city, town, or school district |
| of the state were exempt from any form of tax, then trusts with one or more governmental entities as beneficiaries are |
| exempt from any form of tax. The Attorney General of Oklahoma in his opinion number 77-106 rendered May 27, 1977, |
| applied the statute which exempts from taxation gifts to and income or profits derived by the state or any county, city, |
| town, or school district of the state to exempt public trusts from payment of sales and excise taxes. |
|
Other federal agencies have determined that public trusts created under Oklahoma statutes are political subdivisions of the |
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State of Oklahoma or an agency or instrumentality of such a political subdivision. The Internal Revenue Service |
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inRevenue Ruling 57-151 held that income received by a public trust created under the Oklahoma Statutes would not be |
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subject to federal income tax; it further held that mortgage bonds and debenture notes issued by the public trust would be |
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considered as issued on behalf of the beneficiary of the public trust, a political subdivision, and therefore, interest paid on |
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such bonds was exempt from federal income tax. Additionally, the United States Nuclear Regulatory Commission exempts |
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the * * * from the payment of license fees on the grounds that the * * * is "an agency of a State or any political |
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On the basis of this information, we conclude that the * * * is a political subdivision of the State of Oklahoma or an agency |
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or instrumentality of such a political subdivision within the meaning of Title IV of ERISA, and, consequently, that the Plan |
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is not subject to the provisions of that title. If you have any questions, please contact * * * of my staff at (202) 254- |
|
Henry Rose |
|
General Counsel |