News & Analysis as of

Prohibited Transactions

Robinson Bradshaw

Lower Pleading Standard for 401(k) Plan Prohibited Transaction Suits

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In its April 17 decision in Cunningham v. Cornell University, the U.S. Supreme Court established a plaintiff-friendly standard for ERISA prohibited transaction claims, resolving a circuit court split. As a result, plan...more

Carlton Fields

Considerations for Plan Sponsors in the Wake of Cunningham v. Cornell

Carlton Fields on

Excessive fee cases against plans governed by the Employee Retirement Income Security Act (ERISA) have been on the rise for the last decade. ERISA litigation is expanding with novel theories such as forfeiture litigation....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Do You Really Want to Be an ERISA Fiduciary?

Two recent class action lawsuits charging a breach of fiduciary duty under the Employee Retirement Income Security Act (ERISA) have increased the stakes and raised important considerations regarding a plan fiduciary’s duty of...more

Pullman & Comley - Labor, Employment and...

Employee Benefit Plan Fiduciaries: Why Solid Fee Benchmarking Should Be On Your To-Do List

Certain transactions between employee benefit plans and “parties in interest” are prohibited under the Employee Retirement Income Security Act of 1974, as amended (ERISA). ...more

Maynard Nexsen

Navigating Increased ERISA Litigation Risk Post-Cunningham: How to Protect Your Plan

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Under the Supreme Court’s recent decision in Cunningham v. Cornell University, No. 23-1007 (April 17, 2025), plaintiffs asserting that ERISA plan administrators engaged in prohibited transactions under ERISA Section 406 are...more

Baker Botts L.L.P.

SCOTUS Holds ERISA Requires No Additional Pleading Requirements beyond § 1106 Elements for Prohibited-Transaction Claims,...

Baker Botts L.L.P. on

On April 17, 2025, the Supreme Court of the United States clarified the pleading requirements to bring a prohibited-transaction claim under the Employee Retirement Income Security Act of 1974 (“ERISA”) in Cunningham v....more

Eversheds Sutherland (US) LLP

Supreme Court lowers pleading standard for ERISA prohibited transaction claims

The US Supreme Court issued a unanimous decision on April 17, 2025 that could have a lasting impact on retirement plan litigation. The decision in Cunningham v. Cornell University clarifies that when plaintiffs bring...more

Holland & Knight LLP

2025 Revisions to the VFCP: Key Changes to Correction and Compliance Options

Holland & Knight LLP on

Historically, the IRS' Employee Plans Compliance Resolution System (EPCRS) has provided employers structured options for correcting retirement plan failures. Under this framework, certain operational errors qualified for...more

Lowenstein Sandler LLP

Supreme Court Ruling Makes It Easier for Participants To Sue Plan Fiduciaries

Lowenstein Sandler LLP on

On April 17, the Supreme Court unanimously resolved a circuit split in Cunningham v. Cornell University, holding that plan participants need only allege that fiduciaries engaged in a “prohibited transaction” under the...more

Jackson Lewis P.C.

Supreme Court Clarifies ERISA Prohibited Transaction Pleading Standards

Jackson Lewis P.C. on

On April 17, 2025, the U.S. Supreme Court, in a unanimous opinion, resolved a circuit split and established a plaintiff-friendly pleading standard for ERISA prohibited transaction claims in Cunningham v. Cornell University,...more

ArentFox Schiff

Navigating the DOJ’s New Data Transfer Rule: Implications and Compliance Requirements

ArentFox Schiff on

On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...more

White & Case LLP

DOJ Issues Guidance on Bulk Sensitive Data Rules

White & Case LLP on

On April 11, 2025, the Department of Justice (DOJ) issued guidance (Guidance) to assist individuals and entities in coming into compliance with its final rule, referred to as the "Data Security Program" (DSP Rule), which...more

Littler

The Supreme Court Relieves ERISA Plaintiffs of a Pleading Requirement: What’s Next for ERISA Plan Fiduciaries?

Littler on

On April 17, 2025, the U.S. Supreme Court issued a decision that dealt a blow to benefit plan fiduciaries nationwide. The Court unanimously held in Cunningham v. Cornell University that a plaintiff asserting that a plan and...more

Husch Blackwell LLP

Supreme Court Decision Means Defense of ERISA Prohibited Transaction Claims Just Got More Difficult and More Protracted

Husch Blackwell LLP on

On April 17, 2025, the Supreme Court decided Cunningham v. Cornell University, unanimously holding that a plaintiff can state a valid claim under ERISA by merely alleging that a plan used “plan assets” to pay a service...more

The Volkov Law Group

Practical Issues and the New DSP (Part II of III)

The Volkov Law Group on

Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding.  The DSP framework is new, comprehensive and raises significant risks and requires careful design and...more

Holland & Knight LLP

Supreme Court Ruling Eases Path for ERISA Prohibited Transaction Claims

Holland & Knight LLP on

The U.S. Supreme Court on April 17, 2025, issued a greatly anticipated decision in which the justices unanimously held that plaintiffs alleging a prohibited transaction under Section 1106(a)(1)(C) of the Employee Retirement...more

Miller Canfield

ERISA in the Supreme Court: Implications of Cunningham v Cornell University

Miller Canfield on

On April 17, 2025, the U.S. Supreme Court issued a unanimous opinion in Cunningham v Cornell University, addressing the pleading standard applicable to prohibited transaction claims under the Employee Retirement Income...more

Venable LLP

Supreme Court Endorses Plaintiff-Friendly Prohibited Transaction Pleading Standard

Venable LLP on

On April 17, 2025, the Supreme Court resolved a circuit split on the appropriate pleading standard for a specific type of prohibited transaction claim under ERISA. While that decision may sound dry and technical, the...more

Goodwin

Supreme Court Decides Pleading Standard to Allege ERISA Prohibited-Transaction Claims, Favoring Plaintiffs

Goodwin on

Key takeaway: The Supreme Court held that to state an ERISA prohibited-transaction claim under 29 U.S.C. § 1106(a), a plaintiff needs only to plausibly allege the elements contained in § 1106(a) itself and does not need to...more

The Volkov Law Group

DOJ Issues Data Security Program Requirements (Part I of II)

The Volkov Law Group on

Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more

Seyfarth Shaw LLP

Supreme Court Lowers Bar to Pleading Prohibited Transactions, Despite “Serious Concerns” of Meritless Litigation

Seyfarth Shaw LLP on

In a unanimous decision reversing dismissal of prohibited transaction claims based on fees paid to defined contribution plan recordkeepers, the Supreme Court held that ERISA’s prohibited transaction exemptions are affirmative...more

Winstead PC

The QPAM Exemption - Key Takeaways for Fund Managers with Benefit Plan Investors

Winstead PC on

As an asset manager, you may be familiar with the regulatory issues that come into play when a fund permits investments from “benefit plan investors,” which generally include certain employee benefit plans subject to the...more

Troutman Pepper Locke

Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast

Troutman Pepper Locke on

In the latest episode of Payments Pros, hosts Keith Barnett and Carlin McCrory discuss the latest FinCEN and OFAC guidance on virtual currency transactions, specifically tailored for companies in the payments industry. They...more

Morgan Lewis - ML Benefits

Long Awaited ESOP Proposals Issued and Then Quickly Withdrawn

On January 20, 2025, an executive order froze two new pieces of proposed employee stock ownership plan (ESOP) guidance announced in a notice of proposed rulemaking and originally set for publication in the Federal Register on...more

Proskauer - Employee Benefits & Executive...

New “Self-Correction” Option for Voluntary Fiduciary Correction Starts March 17, 2025

Starting March 17, 2025, the Employee Benefits Security Administration’s Voluntary Fiduciary Correction Program (“VFCP”) will have a “self-correction” option. Although the new option eliminates the need to wait for formal...more

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