"Private equity sponsors should bear in mind that all or a portion of an asset allocation fund's investment could constitute 'plan assets' under ERISA and, therefore, would need to be taken into consideration in determining whether benefit plan investors are 'significant' ... If benefit plan investment is significant, ... the sponsor will need to manage the fund as an ERISA plan asset fund, with appropriate procedures for satisfying ERISA fiduciary, plan asset, and prohibited transaction rules."  MORE >>