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DOL's Citigroup Amicus Brief, in Support of Appellants' Petition for Panel Rehearing
U.S. Department of Labor [DOL] Link to more items from this source
Jan. 26, 2012
The Secretary of Labor, who has primary authority for enforcing and administering Title I of ERISA, ... agrees with the dissent that the panel's holdings represent 'both an alarming dilution' of ERISA 'and a windfall for fiduciaries, who may now avail themselves of the corporate benefits of [ESOPs] without the costs of complying with the statutorily mandated obligations of prudence.' ... The issues are of exceptional importance under Federal Rules of Appellate Procedure ... because they put hundreds of billions of dollars in pension plan assets at undue risk.

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