In Advisory Opinion 2011-05A, the DOL found that it would be permissible to use the proceeds of insurance copay demutualizations where a plan is a policyholder for the benefit of all current participants and beneficiaries, not just those who actually contributed to the premium payments for the insurance policy. The DOL also found that the interests of former participants no longer covered under the plan need not be considered. This guidance is consistent with other DOL guidance on this issue.