This case provides a reminder that courts will look through corporate and legal structures to hold individuals personally liable for egregious breaches of fiduciary duty.  Be very conscious of ERISA’s (1) fiduciary duty of undivided loyalty, (2) the “prudent man” standard, (3) prohibition against self-dealing, and (4) prohibition against transactions “likely to injure a plan” including transactions benefitting a “party in interest.”

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