"[FAB 2026-01] is a positive development for plan sponsors and fiduciaries, as on the whole it suggests a more restrained and targeted enforcement approach: Likely fewer investigations overall, particularly those based on novel or unsettled legal theories or on ESOP valuations. Greater focus on clear-cut violations, especially those involving conflicts of interest or significant participant harm. Increased focus on fiduciary duty of loyalty and reduced emphasis on standalone prudence claims, absent loyalty concerns. More centralized decision-making within EBSA, leading to greater consistency across regions."  MORE >>