News & Analysis as of

Prohibited Transactions

Proskauer - Employee Benefits & Executive...

It’s November 11th, Do You Know When Your Private Investment Fund’s VCOC Annual Valuation Period Is?

Similar to the old school public service announcements that used to tell us the time of day and asked us if we knew where our children were, Proskauer wants to make sure fund managers are complying with their applicable...more

McDermott Will & Schulte

US Treasury’s Outbound Investment Security Program: Lessons and Insights

On January 2, 2025, the US Department of the Treasury’s (Treasury) Final Rule implementing the Outbound Investment Security Program (OISP) pursuant to Executive Order 14105 went into effect, under which US Persons are...more

Mayer Brown

The Evolution of Defined Contribution Plan Class Action Litigation in 2025

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We are entering the home stretch of a memorable year. While benefits litigation may not be the first thing that comes to mind, it has been a very busy year for ERISA class actions, particularly for defined contribution plans...more

Bricker Graydon LLP

When Can You Use the DOL Calculator for Earnings on Plan Corrections?

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When I think of October, I think of pumpkin spice everything, sitting on the sidelines of my kids’ soccer games, football season and retirement plan corrections. ...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Forfeiture Suit Mostly Dismissed — What Plan Fiduciaries Should Know

The latest chapter in the wave of forfeiture reallocation lawsuits comes from Armenta v. WillScot / Mobile Mini. The good news: most of the claims were dismissed. The caution: one prudence claim survived, and the court gave...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Home Depot Wins Forfeiture Fight: Another Court Shuts Down Fiduciary Breach Claims

Chalk up another win for plan fiduciaries in the ongoing wave of forfeiture reallocation suits — and this time, the plaintiffs didn’t even get the courtesy of a do-over....more

Lathrop GPM

Planning for Retirement Accounts that Outgrow Retirement

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Retirement accounts are often the largest financial asset clients hold, yet they are frequently overlooked in estate and investment planning. As these accounts grow and diversify, so do the risks of missteps that can trigger...more

Nutter McClennen & Fish LLP

Second Circuit Rules on Plaintiffs’ Standing and Prohibited Transaction Issues in 401(k) Class Action

The Second Circuit recently made two rulings of interest to ERISA litigators and to fiduciaries of 401(k) or other defined contribution plans. In the first ruling, the court held that individual plan participants did not have...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Bank of America’s Forfeiture Case Survives Motion to Dismiss

One of my favorite movie scenes in Donnie Brasco is when Lefty and the crew bust open city parking meters for dimes because they’ve got to make their weekly nut. Sometimes, I feel like ERISA litigation is the same thing,...more

Carlton Fields

Painting Outside the Lines: New Strokes in ERISA Forfeiture Litigation

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ERISA forfeiture class action litigation has continued to see various developments and potential new theories emerging in 2025. As Carlton Fields has previously reported, starting in late 2023, a new trend of lawsuits emerged...more

Parker Poe Adams & Bernstein LLP

Key Compliance Measures Start This Fall for Companies Under New DOJ Data Security Program

Earlier this spring, the U.S. Department of Justice’s National Security Division (NSD) launched the data security program (DSP). The program is designed to address national security risks posed by foreign adversaries' access...more

Lathrop GPM

[Webinar] Planning for Retirement Accounts that Outgrow Retirement - August 19th, 9:00 am PT

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Lathrop GPM attorneys Allie Itami and Sara Hire will walk through key legal and tax considerations that arise when retirement accounts grow beyond personal retirement needs. From alternative investments to estate tax...more

Kelley Drye & Warren LLP

Simplified Option for Correcting Certain Retirement Plan Failures

Earlier this year, the U.S. Department of Labor (“DOL”) amended its Voluntary Fiduciary Compliance Program (“VFCP”) to provide retirement plan sponsors with a simplified option for correcting certain specified prohibited...more

Mayer Brown

The Current State of the Law in ERISA Forfeitures Cases

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Since September 2023, ERISA plaintiff’s firms have filed approximately 60 class action lawsuits challenging the longstanding practice of plan sponsors using plan forfeitures to offset their employer contributions in 401(k)...more

Verrill

Preparing for “Untoward Practical Results”—Implications and Action Items for ERISA Attorneys Following Cunningham v. Cornell...

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The U.S. Supreme Court’s recent decision Cunningham v. Cornell University, 145 S.Ct. 1020 (2025) significantly lowers the pleading standard for prohibited transaction claims under Section 406(a) of the Employee Retirement...more

Fisher Phillips

Workplace Law Update: 10 Essential Items on Your July To-Do List

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It’s hard to keep up with all the recent changes to labor and employment law, especially since the law always seems to evolve at a rapid pace. To ensure you stay on top of the latest changes and have an action plan for...more

Husch Blackwell LLP

Senate Version of One Big Beautiful Bill Act Clarifies Foreign Entity Restrictions on Renewable Energy Tax Credits

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The Senate Finance Committee recently released its own draft of the “One Big Beautiful Bill Act” (the Bill) previously passed by the House as H.R. 1. Both the House and Senate versions of the Bill impose restrictions on...more

Fisher Phillips

Retirement Plan Fiduciaries Must Adjust to New Era of ERISA Litigation: How a Recent SCOTUS Ruling and $39M Jury Award Changed the...

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A Supreme Court decision in April made it easier for plaintiffs to keep ERISA prohibited transaction claims in play longer, and just days later a rare ERISA trial resulted in a huge win for a class of 401(k) plan...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The whole problem with loans

When I draft a new 401(k) plan for a client, one of the first provisions I’ll recommend—including with some reluctance—is a loan feature. Not because I enjoy dealing with it. On the contrary, it’s an administrative pain. But...more

Bricker Graydon LLP

Don’t Forget About the IRS When Correcting Delinquent Plan Contributions

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Employers that do not timely deposit participant deferrals and loan contributions to their employer sponsored retirement plans can be subject to Department of Labor (DOL) penalties for breaching their fiduciary duties....more

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

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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

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