"The disability durational and claims guidelines that plaintiff requested fall under the ERISA section 1133 regulations because, construing the facts in favor of plaintiff, they were 'relied upon' or at least 'considered ... in the course of making [plaintiff's] benefit determination.' Indeed, that is the very reason plaintiff seeks them.... Nothing in the text of the ERISA statute or regulations indicates that section 1132(c) penalties are available for violations of section 1133 or its regulations, and section 1133 does not provide for penalties." [Marcin v. Reliance Standard Life Insurance Company, No. 13-1308 (D.D.C. June 20, 2014)]  MORE >>