The Department of Labor (DOL) recently advised that a program under which Citigroup Inc. (Citi) subsidizes investment management fees for its employee benefit plans’ diverse investment managers could be implemented without unfavorable consequences under the fiduciary and prohibited transaction provisions of ERISA. Advisory Opinion 2023-01A, issued on September 29, 2023, provides plan sponsors with a potential pathway to support the use of diverse investment managers in a manner that is consistent with ERISA.