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Door Closes on SPD-Based Benefits Claims, but Plaintiffs See New Hope for Relief
Ballard Spahr LLP [Guidance Overview] May 25, 2011 The Court described three types of relief against fiduciaries that were traditionally available in equity and, hence, should be available under Section 502(a)(3): (1) reformation of contract to remedy fraud or mistake, (2) estoppel to remedy fraudulent misrepresentation, and (3) compensation for a loss resulting from a fiduciary's breach or to prevent a fiduciary's unjust enrichment (a/k/a 'surcharge'). |
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