PHILADELPHIA - A nonfiduciary financial planner who marketed a tax avoidance scheme as a multiple employer welfare arrangement (MEWA) to several employers is liable under Employee Retirement Income Security Act (ERISA), 29 U.S.C.S. § 1001 et seq. Section 502(a)(3) for knowingly participating in a prohibited transaction in connection with the MEWA, the Third Circuit U.S. Court of Appeals ruled Nov. 8 (National Security Systems, Inc., et al. v. Robert L. Iola, Jr., et al., Nos. 10-4154, 10-4155, 3rd Cir.; 2012 U.S. App. LEXIS 23063).