The ISAS Group Benefits Trust (the “Trust”) was established in November 1989 by three member schools and the Independent Schools Association of the Southwest (the “ISAS”) office with the goal of providing a self-insured medical and dental plan for ISAS member school employees and their dependents. The Trust has since expanded to offer fully insured vision, long-term disability and life insurance plans.The Trust is a tax-exempt Voluntary Employees’ Beneficiary Association (“VEBA”) under Section 501(c)(9) of the Internal Revenue Code of 1986, as amended, and a Multiple Employer Welfare Arrangement (“MEWA”) as defined in Section 3 of the Employee Retirement Income Security Act of 1974, 29 U.S.C., Section 1002(40)(A), as amended. The ISAS is a 501(c)(3) tax-exempt educational association of 85 member schools in Texas, Oklahoma, Louisiana, New Mexico, Arizona and Kansas. The Trust currently has 25 Participating Employers located in Texas and Oklahoma, and provides benefits to approximately 3,500 employees and 5,900 total individuals. The Trust operates as a Benefits Consortium under Title 6 of the Texas Education Code and is governed solely by the Employee Retirement Income Security Act of 1974 (29 U.S.C., Section 1001 et seq.), after having surrendered its Certificate of Authority to operate as a MEWA in the State of Texas pursuant to Chapter 846 of the Texas Insurance Code in August 2008. The Trust also currently maintains a license to operate as an exempt-MEWA in the State of Oklahoma pursuant to Title 36 O.S §635.