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One of our plans has a trustee who until very recently was receiving full-time pay from a contributing employer. This made him ineligible to receive compensation for the time he spent on plan business (meetings, conferences, etc.) This person has now retired and wants to be paid for his time. He is drawing a monthly annuity from the plan in question.

My understanding of ERISA 406 and 408 is that a fiduciary may receive "reasonable compensation" for services rendered so long as he does not receive full-time pay from an "employer, or association of employers whose employees participate in the plan, or from an employee organization whose members participate in the plan." The plan itself does not fall under the definition of "employer, employer association or employee organization." Therefore, it appears to me he may receive compensation for fund business

Am I overlooking anything? Is this analysis correct?

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