A Fourth Circuit decision (unpublished) which you can access here provides an interesting discussion of the statute of limitations issues that can arise with respect to bringing suit under ERISA for plan losses resulting from a Ponzi scheme. The case provides a summary of the various Courts of Appeals’ positions on the issue of what constitutes “actual knowledge of the breach or violation” under Section 413 of ERISA.
In addition, as Eleanor Roosevelt once said: “Learn from the mistakes of others. You can