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DOL Settlement with ING Regarding Trading Error Correction Gains (PDF)
Groom Law Group 
Feb. 7, 2013
"[It] has been [ING]'s practice to keep the gains resulting from the correction of an error in two instances ... The DOL alleged that [ING]'s failure to disclose its transaction error correction policy resulted in it receiving compensation in violation of ERISA. As part of the settlement, [ING] must make full disclosure of its investment transaction policy to both current and prospective clients who are subject to ERISA... [ING] is further obligated to inform clients that it will track, on an annual basis, the effect the corrections have on each plan[.]"
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