"The Fourth Circuit [held] that a participant or beneficiary is generally not required to allege that the plan administrator and named fiduciary also satisfies a functional fiduciary test to state a plausible fiduciary breach claim. Nevertheless, the court also concluded that, even if named fiduciary status was not enough to subject the employer to fiduciary responsibilities, the employer’s alleged conduct satisfied the functional definition of a fiduciary." [Dawson-Murdock v. National Counseling Group, Inc., No. 18-1989 (4th Cir. Jul. 24, 2019)]