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Cybersecurity Guidance Welcome, But Unanswered Questions Remain
The Wagner Law Group 
[Guidance Overview] July 26, 2021 "What personal information and/or confidential information must be safeguarded by plan administrators and other plan fiduciaries to comply with ERISA's fiduciary standards? ... For purposes of misappropriation of PPI, is PPI a plan asset under ordinary notions of property rights? Does the resolution of this question affect the application of ERISA Section 404 to protect PPI? ... What losses due to cybersecurity breaches in plans' or the plan service providers' systems are covered by a bond under ERISA Section 412 and implementing regulations?" |
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