BUFFALO, N.Y. - The "fraud or concealment" exception to the six-year statute of limitations set forth in Employee Retirement Income Security Act Section 413 did not apply to toll claims that pension and welfare plans' trustees breached their fiduciary duties by failing to monitor the plan managers, a federal judge in New York ruled Oct. 2 (Douglas A. Janese, et al. v. Santo S. Scrufari, et al., No. 09-cv-593, W.D. N.Y.; 2013 U.S. Dist. LEXIS 142888).