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What Employers Need to Know About SPDs and Other Plan Communications After Supreme Court's Decision in CIGNA Corp. v. Amara
Cooley LLP 
[Guidance Overview] June 23, 2011
The opinion does not offer details on what kinds of actual harm a participant must prove. Nor is it clear whether the amount of compensation available under an equitable relief claim would be similar to what a participant would receive under the pre-Amara rule adopted by many lower courts of requiring enforcement of the SPD as if it were the plan.
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