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A Deadline Is a Bright Line: Seventh Circuit Narrows 'Substantial Compliance'
Jackson Lewis P.C. July 2, 2019
"Although the court held that a plan administrator that misses a statutory deadline cannot be in 'substantial compliance' with the statute, the Seventh Circuit ... refused to abrogate entirely the doctrine of 'substantial compliance.' Rather, the court narrowly held that the doctrine does not apply to the violation of regulatory deadlines, so 'when that time is up, it's up.' " [Fessenden v. Reliance Standard Life Ins. Co., No. 18-1346 (7th Cir. Jun. 25, 2019)]
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