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The fiduciary standards of ERISA apply to all employee benefit plans that are subject to Title I of ERISA. The duty of loyalty, the duty of prudence, and the duty to administer a plan in accordance with its written terms apply equally to “employee welfare benefit plans” and “employee pension benefit plans,” differences in specific fiduciary activities notwithstanding. This has been true since ERISA was signed into law 47 years ago, yet even the most compliance-oriented employers seem to apply a lighter fiduciary touch when it comes to welfare benefit plans. Most well-advised employers have robust fiduciary governance structures for their retirement plans built around administrative and investment committees, which have adopted written charters and meet regularly. Yet many of these same employers make important fiduciary decisions with respect to their welfare benefit plans – such as the selection and monitoring o