"[U]nder the Racial Equity Program, Citi pays 'all or some' of the investment management fees for 'Diverse Managers' if they are retained by Citi's own ERISA covered employer-sponsored benefit plans.... Advisory Opinion 2023-01A assumed that the Racial Equity Program was lawful and went on to discuss fiduciary issues that follow from that assumption. But the Racial Equity Program is not lawful -- its allocation of benefits on the basis of race clearly and unambiguously violates the civil rights laws.... Citi should take immediate action to end all illegal activity within its Racial Equity Program and any other initiative, plan, program, or scheme it operates under the banner of diversity, equity, and inclusion. ERISA does not shield Citi or the fiduciaries of the Plans from the application of the civil rights laws."  MORE >>