The Seventh Circuit Court of Appeals has joined with the Third Circuit in holding that a retirement plan established and maintained by a church-affiliated hospital system is not within the statutory definition of a “church plan” exempt from the requirements of the Employment Retirement Income Security Act (“ERISA”). ( See Nonprofit Issues , Employment Law, 2/16. ) Like the Third Circuit, the Seventh Circuit has held that only a plan established by a church, and not one established by a church-affiliated agency, can qualify under the definition of the statute. It has ruled this way despite “long-standing and abundant” private letter rulings from the Internal Revenue Service holding that...