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Hardly Strict Tracing after the 2006 Sereboff Opinion
Seyfarth Shaw LLP Link to more items from this source
Feb. 25, 2014
"[For] most of the country, if an ERISA plan's terms allow for reimbursement from a beneficiary, the likely outcome in most cases will be that the recovery will be permitted, even if the funds cannot be strictly traced. However, ERISA plan sponsors and insurers in the Ninth Circuit must be prepared to face a higher hurdle when attempting to recover funds from a beneficiary."

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