The Employee Retirement Income Security Act of 1974—commonly referred to as ERISA— covers a wide range of benefit plans: retirement, health (or vision or dental) insurance, disability insurance, employee stock ownership, and flexible spending accounts. Under ERISA, those providing services to plans are subject to a range of requirements in carrying out their duties.
A recent decision of the U.S. Court of Appeals for the Fourth Circuit highlights the fiduciary responsibilities of plan administrators, but also the potential ERISA liability of those providing services as subcontractors to employee benefit plans.
ERISA’s Civil Enforcement Scheme
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