Am. Sec. Ass'n v. United States DOL

Am. Sec. Ass'n v. United States DOL

Opinion

ORDER

This matter comes before the Court upon consideration of Plaintiff American Securities Association's Motion for Summary Judgment (Doc. # 39), filed on May 20, 2022, and Defendants United States Department of Labor and Marty Walsh's Amended Motion to Dismiss for Lack of Jurisdiction or, in the Alternative, for Summary Judgment (Doc. # 49), filed on June 30, 2022. All Motions have been fully briefed (Doc. ## 49, 50, 53) and are ripe for review. For the reasons that follow, Defendants' Motion to Dismiss is denied, and both summary judgment Motions are granted in part and denied in part.

I. Background

This case arises out of a challenge [*2]  to guidance promulgated by the Department of Labor interpreting its Prohibited Transaction Exemption 2020-02, 85 Fed. Reg. 82798 (December 18, 2020) (the "2020 Exemption"). The 2020 Exemption governs the circumstances in which financial institutions and investment professionals who provide "fiduciary investment advice" to retirement investors can "receive otherwise prohibited compensation." (JA Doc. # 54-1 at 66).

A. ERISA

Congress enacted the Employee Retirement Income Security Act of 1974 ("ERISA") following a determination that Americans' retirement savings were not adequately protected. Pub. L. No. 93-406, 88 Stat. 829, 898 (1974) (codified at 29 U.S.C. §§ 1001, et seq.). ERISA's statutory framework includes enhanced "disclosure and reporting" requirements, "standards of conduct, responsibility, and obligation for fiduciaries of employee benefit plans," and "appropriate remedies, sanctions, and ready access to Federal courts." 29 U.S.C. § 1001(b); Ali v. Cal. Field Ironworkers Trust Fund, No. 8:09-cv-1031-VMC-EAJ, 2010 U.S. Dist. LEXIS 11613, 2010 WL 358539, at *2 (M.D. Fla. Jan. 23, 2010) (citing Aetna Health, Inc. v. Davila, 542 U.S. 200, 208, 124 S. Ct. 2488, 159 L. Ed. 2d 312 (2008)).

Title I of ERISA imposes stringent obligations on fiduciaries of employee benefit plans. See 29 U.S.C. § 1104 (detailing fiduciary duties under ERISA). An individual is a fiduciary with respect to a plan under ERISA to the extent:

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