After over two decades of Supreme Court decisions dealing with the Federal Arbitration Act (FAA), 9 U.S.C. Section 1 et seq., it is clear that FAA-covered pre-dispute arbitration agreements dealing with statutory claims are enforceable "as written." It is also clear that such agreements will not be enforced if they require waiver of a statutory claim or right. The Second Circuit's recent (2-1) decision in Cedeno v. Sasson, No. 21-2891-cv (2d Cir., May 1, 2024), affirmed District Court Judge John G. Koeltl's order refusing to enforce an arbitration agreement because its terms required a waiver of an ERISA plan beneficiary's right to pursue a claim against the plan fiduciaries for plan-wide relief under ERISA Sections 502(a) and 409(a), 29 U.S.C. Sections 1109(a); 1132(a).