Excerpt: The Enforcement Manual carves out two circumstances where investigators are generally to conclude that no violation of ERISA § 406(b)(3) has occurred: (1) $250 de minimis amount: where a fiduciary and its family members receive consideration (i.e., gifts, gratuities, meals, entertainment, other non-cash consideration, or reimbursement of expenses associated with educational conferences) of an aggregate annual value of less than $250 and their receipt does not violate any plan policy or provision; (2) Educational expenses: where the plan is reimbursed for expenses associated with a plan representative's attendance at an educational conference, provided that:[.]

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