Abstract
The Employee Retirement Income Security Act of 1974 (ERISA)2 is a comprehensive federal law regulating the private employee benefit system.3 Congress enacted ERISA to address concerns that abuses in the management of pension plans caused the wrongful denial of benefits to workers. The enactment of ERISA provided for a means to ensure that benefits promised to workers would be paid.5 Congress hoped that ERISA would meet this goal by
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