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Prohibited Transactions Fiduciary Duty

Littler

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

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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

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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

Holland & Knight LLP

Supreme Court Ruling Eases Path for ERISA Prohibited Transaction Claims

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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

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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

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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

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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

Seyfarth Shaw LLP

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

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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

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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

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

Morgan Lewis

DOL’s VFCP Final Rule Adds Limited ‘Self-Correction’ Program for Late Contributions, Participant Loan Failures

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The Employee Benefits Security Administration recently released its final rule amending and restating the Voluntary Fiduciary Correction Program, along with corresponding amendments to a related class exemption, Prohibited...more

Holland & Knight LLP

The Rise and Fall of the DOL's Long-Anticipated Proposed Regulation on "Adequate Consideration"

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The U.S. Department of Labor (DOL) on Jan. 16, 2025, released its long-awaited proposed regulation interpreting the definition of "adequate consideration" as applied to private company stock acquired or sold by an employee...more

Groom Law Group, Chartered

DOL Finalizes Update to Voluntary Fiduciary Correction Program

On January 15, 2025, the Department of Labor (“DOL”) issued notice amending its Voluntary Fiduciary Correction Program (“VFCP”), along with related final amendments to Prohibited Transaction Exemption 2002-51 (“PTE 2002-51”),...more

Shipman & Goodwin LLP

Plan Forfeiture Litigation: A Trend to Watch

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The most recent wave of ERISA litigation is focused on the use of plan forfeitures in 401(k) plans, with the newest case, Armenta v. WillScot Mobile Mini Holdings Corp. being filed just last week. Although, for years, many...more

McDermott Will & Emery

Trump Places DOL’s ESOP Proposals in Regulatory Moratorium

On January 16, 2025, the US Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) released two pieces of guidance that, if finalized, would dramatically change the landscape for fiduciaries responsible...more

Pullman & Comley - Labor, Employment and...

Retirement Plan Update – Forfeitures are New Focus of Fiduciary Breach Litigation

Many employer-sponsored defined contributions plans, including 401(k) profit sharing plans and money purchase pension plans include a vesting schedule – a period over which a plan participant earns a nonforfeitable right to...more

DLA Piper

Supreme Court Debates ERISA Exemptions in Cunningham v. Cornell University

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The US Supreme Court heard argument on Wednesday, January 22, 2025 from Cornell University and its employees over dismissal of a class action alleging that Cornell University’s retirement plan paid unreasonable recordkeeping...more

Carlton Fields

The Case of Excessive Fees: Supreme Court to Investigate Pleading Standard in ERISA Excessive Fee Litigation

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ERISA class action litigation against retirement plan fiduciaries remains a prominent feature of the legal landscape this year. These lawsuits typically involve allegations that plan fiduciaries acted imprudently in...more

Kilpatrick

DOL Finalizes VFC Program Self-Correction Component for Late Deposits and Loan Failures

Kilpatrick on

On January 14, 2025, the US Department of Labor (“DOL”) released a final regulation revising its Voluntary Fiduciary Correction (“VFC”) Program and related prohibited transaction exemption (“PTE”) 2002-51 to add a...more

Polsinelli

Prohibited Transaction Pleading Standards To Receive Clarity From SCOTUS

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Key Takeaways - In October 2024, SCOTUS granted review of Cunningham v. Cornell University to provide guidance on certain pleading standards in ERISA litigation claims, with oral arguments scheduled for January 2025....more

K&L Gates LLP

QPAM Amendments Impact on CITs: What Banks and Their Advisers Need to Know

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Effective 17 June 2024, the US Department of Labor (DOL) adopted comprehensive amendments to Prohibited Transaction Exemption (PTE) 84-14, also known as the “QPAM exemption” (Exemption)....more

Lathrop GPM

The Year Ahead for Compensation & Benefits - 2025

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As 2024 winds down, many are wondering what 2025 may bring in the world of compensation and benefits. Our ERISA attorneys use their decades of experience and crystal balls to predict what may be on horizon in plan design and...more

Carlton Fields

Changes for Producer Award Trips at IMOs? Fiduciary Rule Suggests Turbulence Ahead

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In April 2024, the U.S. Department of Labor issued its long-awaited retirement security rule, also known as the fiduciary rule, broadening the definition of who is an “investment advice fiduciary” under the Employee...more

Faegre Drinker Biddle & Reath LLP

Rollover Recommendations: PTE 2020-02 Compliance Considerations Following the DOL Fiduciary Rule Stay

The effective date of the DOL’s new expansive fiduciary rule and the amendments to Prohibited Transaction Exemption (PTE) 2020-02 has been stayed pending the outcome of the lawsuits challenging the rule and the amended PTE....more

The Wagner Law Group

District Court Grants Motion to Dismiss Forfeiture Complaint

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Last year, we alerted you to the filing of several class action lawsuits alleging that plan fiduciaries violated their duties of prudence and loyalty under Title I of ERISA by using forfeitures to reduce employer...more

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