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Nonprofit Group Disability plan is not a "Church Plan" exempt from ERISA.

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Nonprofit and Church Legal Trends - Free Edition - July August 2008 (free edition)

The group disability insurance policy maintained by a nonprofit religious organization that trains Bible study teachers but does not provide worship services or is registered as a church is not a “church plan” and is therefore governed by the Employment Retirement Income Security Act and subject to federal court jurisdiction, according to a federal District Court in Tennessee.