"Permitting a fiduciary to enforce an equitable lien only against identified third-party recovery funds in the defendant's possession is consistent with ERISA's design. To be sure, in some cases, the beneficiary's disposition of the funds will prevent the fiduciary from recovering the reimbursement to which it is entitled. But that possibility has been clear since Great-West, and Congress has not acted to override this Court's construction of Section 502(a)(3) in reimbursement cases." [Nat. Elevator Indus. Health Benefit Plan v. Montanile, No. 14-11678 (11th Cir. Nov. 25, 2014; cert. pet. granted Mar. 30, 2015)]  MORE >>