"Hitchcock left your imagination to do the dirty work. He knew that your imagination could fill in expertly placed gaps.... But when there are gaps left in ERISA plans, we end up with much worse than just a start.... [I]t is important to recognize that liability that is already out there cannot be put back in the bottle.... [E]mploy a process to insure that you have done and are doing what you promised you would do.... [E]mploy a system to utilize exemptions in the proposed Department of Labor Fiduciary Rule."  MORE >>