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Banking Law Keyed to Barr, 3rd Ed.
Tibble v. Edison International
Citation:
135 S. Ct. 1823 (2015)Facts
In 2007, beneficiaries of Edison International’s 401(k) Savings Plan filed a lawsuit alleging that the company and other fiduciaries breached their duties by offering six higher-priced retail-class mutual funds when materially identical lower-priced institutional-class funds were available. Three funds were added to the Plan in 1999, and three were added in 2002. The plaintiffs argued that a large institutional investor like the Plan could have obtained the same funds at lower prices available to institutional investors, and the higher fees unnecessarily reduced participants’ retirement savings. The District Court agreed regarding the 2002 funds but ruled that claims about the 1999 funds were time-barred under ERISA’s six-year statute of limitations. The Ninth Circuit affirmed, holding that only a significant change in circumstances could trigger a new breach within the limitations period.
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