Congress’ stated purpose for enacting the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1001 et seq. (ERISA), was to “protect…participants in employee benefit plans and their beneficiaries…by establishing standards of conduct, responsibility, and obligation for fiduciaries of employee benefit plans, and by providing for appropriate remedies, sanctions, and ready access to the federal courts.” 1 Following the U.S. Supreme Court’s decision in Pilot Life Insurance Co. v. Dedeaux, 481 U.S. 41 (1987), the […]