"A magistrate judge rejected Frank's core contention that ERISA bars the government's seizure of his 401(k) account, noting that the key question was 'whether the [Mandatory Victims Restitution Act's] directive mandating victim restitution trumps ERISA's robust protection of retirement funds'--concluding that it does. He also noted that that reading was consistent with the view of every court of appeals and district court to have considered the issue.... The district court accepted nearly all of the magistrate judge's findings ... The appellate court concurred[.]" [United States v. Frank, No. 20-6706 (4th Cir. Aug. 10, 21)]