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SPD at Disablement Sets Standard of Review
Blogging Employee Benefits 
Mar. 16, 2006
Excerpt: The SPD in effect when an individual became disabled and entitled to disability benefits, not an amended SPD in effect later upon benefit denial, establishes the appropriate standard of judicial review of a plan administrator's benefits determination, according to a 2nd Circuit ruling reversing a district court decision. [Gibbs v. Cigna, No. 05-3879]
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