Analysis
What the administration claimed
The U.S. Department of Labor filed an amicus brief in Stana v. SAS Institute Inc. arguing the plan fiduciary did not violate its duty of loyalty by using forfeited funds to reduce employer matching contributions and noting SAS generally used forfeitures to reduce matching contributions between 2018 and 2023, but in 2022 allocated $222,320 of forfeitures to plan expenses.
Claimant: U.S. Department of Labor U.S. Department of Labor (EBSA)
Agency or office: U.S. Department of Labor
Context
Press release summarizing the Department's amicus brief in a pending Fourth Circuit case about whether plan forfeitures must be used to pay plan expenses or whether a plan fiduciary may allocate them to reduce employer matching contributions when the plan grants the fiduciary discretion.
Evidence
The department's release describes the position it took in its amicus brief (a legal argument urging the court to affirm dismissal) and summarizes factual assertions from the brief about SAS's historical use of forfeitures and the specific $222,320 allocation in 2022. This is a consequential legal position about interpretation of ERISA and the factual record of the case.