News & Analysis as of

Benefit Plan Sponsors Prohibited Transactions

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

Bricker Graydon LLP

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

Bricker Graydon LLP on

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

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

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

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

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

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

Shipman & Goodwin LLP

Plan Forfeiture Litigation: A Trend to Watch

Shipman & Goodwin LLP on

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

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

Polsinelli

Prohibited Transaction Pleading Standards To Receive Clarity From SCOTUS

Polsinelli on

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

Holland & Knight LLP

Supreme Court to Reevaluate Pleading Requirements for ERISA-Prohibited Transaction Claims

Holland & Knight LLP on

The U.S. Supreme Court recently granted a petition for a writ of certiorari to review the U.S. Court of Appeals for the Second Circuit's decision in Cunningham v. Cornell University, 86 F.4th 961 (2d Cir. 2023). In doing so,...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (40): Rollovers and the Insurance License Issue

The Department of Labor’s final regulation defining fiduciary status for investment advice to retirement investors will be effective this September 23. Where a fiduciary recommendation results in additional compensation for...more

Verrill

Novel 401(k) Plan Lawsuits Over the Use of Forfeitures—Swinging for the Fences or Plausible Claims?

Verrill on

In our December 7, 2023 post, we noted five class action lawsuits, all filed by the same law firm within two months, in which 401(k) plan participants allege plan fiduciaries violated ERISA by using plan forfeitures to offset...more

Proskauer - Employee Benefits & Executive...

A Pop Culture Guide to the Final Amendments to the QPAM Exemption Taking Effect on June 17, 2024

The DOL recently finalized amendments to the QPAM exemption that will considerably alter the exemption’s conditions effective as of June 17, 2024 (for a detailed summary of the changes, please see our post here). There are a...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule and Amended PTE 2020-02: Effective Date Considerations

The DOL’s new fiduciary advice rule, effective September 23, 2024, will cause many one-time recommendations to be fiduciary advice. As a result, many more recommendations to retirement investors—private sector retirement...more

Morgan Lewis

DOL Publishes QPAM Exemption Amendments: Action Items and Considerations for QPAMS, Plan Sponsors

Morgan Lewis on

The US Department of Labor (DOL) published final amendments to Prohibited Transaction Class Exemption 84-14, the so-called “QPAM Exemption,” in the Federal Register on April 3, 2024. The amendments are anticipated to affect...more

Eversheds Sutherland (US) LLP

Department of Labor’s final Fiduciary Rule 4.0

On April 23, 2024, the US Department of Labor (DOL) released its Final Rule 4.0 regarding ERISA fiduciary investment advice, including amended exemptions for conflicted investment advice. Our initial analysis of the Final...more

Davis Wright Tremaine LLP

Labor Department Finalizes Investment Advice Fiduciary Rule Under ERISA

For the second time in a decade, the Department of Labor (DOL) attempted to expand the reach (and requirements) of the Employee Retirement Income Security Act of 1974 (ERISA). On April 23, 2024, DOL succeeded and announced...more

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

How Has the DOL’s Fiduciary Rule Affected Plan Sponsors?

What has changed with the U.S. Department of Labor’s (DOL) final regulations and certain prohibited transaction exemptions (PTEs)? Is it really that bad even for plan sponsors, as we hear from the many critics of the DOL’s...more

K&L Gates LLP

QPAM Exemption Amendment—Key Takeaways and Action Steps for Advisors and Other Stakeholders

K&L Gates LLP on

Executive Summary - Many investment advisers and other financial institutions rely on the Department of Labor’s QPAM Exemption when providing services to, and transacting with, employer-sponsored retirement plans, individual...more

Goodwin

The Department of Labor Finalizes Changes to the QPAM Exemption - A Favored Management Tool Gets Less User-Friendly

Goodwin on

On April 3, 2024, the Department of Labor (DOL) published final changes to Prohibited Transaction Class Exemption 84-14, commonly known as the “QPAM Exemption”. The changes make reliance on the QPAM Exemption more burdensome...more

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