Hi SHVC,
I've gotta say that what "Littlebird" posted seems about exactly on the money to me. Not way off the mark at all. Except the part about 2 years - it was more like 18 months as I recall (April 2016).
The VARA EBA applies because it was in place, when the employer transfer was c/o. It does not mean the employer is VARA, just because VARA T&Cs are in place. Governance is most certainly VAA for the ATR operation, but it remains a "hybrid" in some systems and admin processes.