2003-02A (Feb. 10, 2003). Excerpt: This is in response to your request ... regarding the fiduciary responsibility provisions of [ERISA]. Specifically, you have requested an opinion clarifying the application of sections 408(b)(2) and 408(b)(6) ... to the provision of overdraft protection services, including any inherent extension of credit incident to such services, by banks, whether or not the bank or other financial institution or affiliate exercises investment discretion over plan assets.  MORE >>