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New York City District Council of Carpenters Benefit Funds
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Pollard & Associates
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Seventh Circuit: Plan's Forum-Selection Clause Is Not Precluded by ERISA (PDF)
U.S. Court of Appeals for the Seventh Circuit Aug. 11, 2017
"With support from the Secretary of Labor, Mathias argues that forum-selection clauses in plan documents are categorically invalid because they deprive plan participants and beneficiaries of the right to select from the menu of venue options offered by Section 1132(e)(2).... [F]orum-selection clauses promote uniformity in plan administration and reduce administrative costs and in that sense are consistent with the broader statutory goals of ERISA.... The forum-selection clause in the Caterpillar plan chooses from among the venue options listed in Section 1132(e)(2), and nothing in the statute makes that choice invalid. Accordingly, we hold that the plan's forum-selection clause is enforceable." [In re Mathias, No. 16-3808 (7th Cir. Aug. 10, 2017)]
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