Board of Trustees for the Alaska Carpenters Defined Contribution Trust Fund v. Principal Life Insurance Company

CourtDistrict Court, W.D. Washington
DecidedNovember 3, 2023
Docket2:22-cv-01337
StatusUnknown

This text of Board of Trustees for the Alaska Carpenters Defined Contribution Trust Fund v. Principal Life Insurance Company (Board of Trustees for the Alaska Carpenters Defined Contribution Trust Fund v. Principal Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Trustees for the Alaska Carpenters Defined Contribution Trust Fund v. Principal Life Insurance Company, (W.D. Wash. 2023).

Opinion

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3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 THE BOARD OF TRUSTEES FOR CASE NO. 22-cv-01337 8 THE ALASKA CARPENTERS DEFINED CONTRIBUTION TRUST ORDER ON MOTION TO 9 FUND, DISMISS

10 Plaintiff, v. 11 PRINCIPAL LIFE INSURANCE CO., an Iowa Company, 12 Defendant. 13 14 1. INTRODUCTION 15 This is an ERISA case. Plaintiff The Board of Trustees for the Alaska 16 Carpenters Defined Contribution Trust Fund (“The Board”) sues Defendant 17 Principal Life Insurance Co. (“Principal Life”), alleging Principal Life breached its 18 fiduciary duties and contract with the Board as the plan’s former administrator. 19 Dkt. No. 1. Principal Life moves to dismiss the complaint arguing the Board fails to 20 state a claim. Dkt. No. 14. The Court disagrees and DENIES the motion as 21 explained further below. 22 23 1 2. BACKGROUND 2 The facts below are taken from the Board’s complaint, which the Court

3 accepts as true on review of Principal Life’s Rule 12(b)(6) motion. Bafford v. 4 Northrop Grumman Corp., 994 F.3d 1020, 1024 (9th Cir. 2021) (citing Curtis v. 5 Irwin Indus., Inc., 913 F.3d 1146, 1151 (9th Cir. 2019)). 6 The Alaska Carpenters Defined Contribution Trust Fund (“Trust”) is a trust 7 fund that sponsors a multi-employer individual account or defined contribution 8 plans for carpenters and their families. Dkt. No. 1 ¶ 1.1. The Board administers the

9 Trust as its named fiduciary. Id. The Board consists of ten unpaid volunteers, and 10 the Trust has no employees, so the Trust contracts with third-party administrators 11 for its day-to-day operations like receipt of contributions, confirmation of 12 contributions, enrollment and eligibility determinations, beneficiary record 13 maintenance, financial accounting, and assistance with distributions. Id. ¶¶ 3.1– 14 3.2. 15

16 17 18 19 20 21

22 23 1 In 2011, the Trust entered a Master Services Agreement with Wells Fargo 2 Bank, N.A. for recordkeeping and administrative services, including recordkeeping

3 of participant accounts, asset custody, trust fund reporting, processing 4 distributions, and distribution of certain participant notices. Id. ¶ 3.3. The Board 5 did not attach the Master Services Agreement to its Complaint. But it alleges that 6 under the agreement, Wells Fargo would receive an annual fee of $55.00 per 7 participant account, billed to the Board monthly. Id. ¶ 3.4. If the plan’s investment 8 managers paid the plan revenue sharing amounts, those amounts were to be

9 deposited to a reserve account and used “pursuant to written direction to Wells 10 Fargo.” Id. 11 The Trust and Wells Fargo amended the Master Services Agreement several 12 times, including in 2014, 2015, 2020, and 2021. Id. ¶¶ 3.5–3.7. The amendments all 13 dealt with how fees would be calculated and paid to Wells Fargo. In 2014, the Trust 14 and Wells Fargo amended the Master Services Agreement “to add an asset-based 15 fee between 10 basis points and 35 basis points to cover” various costs, including the

16 Trust’s third-party administrator, attorney, auditor, investment consultant, 17 insurance, and “other plan-related expenses.” Dkt. No. 1 ¶ 3.5. Like the “revenue 18 sharing amounts,” “the asset-based fee was to be paid to a reserve account and 19 subsequently used to pay qualified plan expenses pursuant to written direction to 20 Wells Fargo.” Id. 21 The Trust and Wells Fargo amended the Master Services Agreement again in

22 January 2015. This time to change the “asset-based fee to a flat 20 basis point fee 23 (inclusive of revenue sharing) . . . .” Id. ¶ 3.6. Additionally, Wells Fargo agreed “to 1 create a separate reserve account for the revenue sharing amounts and directed 2 that the asset-based fee be paid to this reserve account.” Id. The “fees and expenses

3 described in the amendment ‘constitute[d] amounts payable to Wells Fargo Bank.’” 4 Id. Despite repeated references in the Master Service Agreement and its various 5 amendments to amounts payable to Wells Fargo, “the understanding and practice 6 between the parties was that the asset-based fee was designated solely to pay plan 7 expenses, other than Wells Fargo’s fee.” Id. In other words, the Board alleges, at no 8 time did Wells Fargo pay itself the asset-based fee.

9 Effective January 2020, the Trust and Wells Fargo amended the Master 10 Services Agreement yet again. Id. ¶ 3.7 This amendment reduced the asset-based 11 fee to 15 basis points and the account fee from $55 to $50 per participant. Id. “[T]he 12 practice regarding the allocation and use of the asset-based fee remained 13 unchanged” otherwise. Id. 14 In the meanwhile, Principal Life bought Wells Fargo’s recordkeeping 15 business in May 2019. At the time, Wells Fargo’s Client Relationship Manager,

16 Mark Thomas, informed the Board that the Trust “would be transitioning” to 17 Principal Life and that Wells Fargo’s fees would not change. Id. at ¶ 3.9. In 18 February 2020, Thomas sent a written request to the Fund for its consent to assign 19 “its Wells Fargo agreement to Principal.” Id. Thomas stated, “Except as 20 specifically stated otherwise in the Consent, all terms and conditions of the 21 Agreements, including amounts charge [sic] for any services, will remain

22 the same at the time of the transfer to Principal.” Id. (emphasis in complaint). 23 1 About a year later, Thomas emailed the Trust’s attorney, Frank Morales, 2 about updating Wells Fargo’s fee schedule for “AK Carpenters” and “chang[ing] the

3 administrative procedures to combine the expense accounts” for the move to 4 Principal Life. Id. ¶ 3.10. Thomas included “an agreement” with his email that did 5 not include the “reserve account,” but “the remaining language in the agreement 6 was largely unchanged.” Id. 7 Thomas and Morales also spoke on the telephone that day, with Thomas 8 telling Morales that “Principal preferred to credit the revenue sharing amounts

9 directly back to participant accounts rather than use them to offset plan expenses . . 10 . [and] if the revenue sharing amount were paid back to plan participants there was 11 no need to reference the reserve account in the agreement.” Id. ¶ 3.11. The Board 12 further alleges that Thomas assured Morales “that proposed fee changes consisted 13 solely of change to the revenue sharing and that the fees payable to Wells Fargo 14 and to Principal, by assignment, were not increasing.” Id. ¶ 3.11. 15 On May 20, 2021, Morales provided the Board with the “requested

16 amendment to the fee schedule.” Id. ¶ 3.12. The Board contends Morales “conveyed 17 the information that Thomas told him, namely ‘This agreement is to clean-up some 18 items in anticipation of the transition to Principal. The fees are not changing, other 19 than that the rebates will no longer be used to pay for any administrative 20 expenses.’” Id. Thomas did not inform the Trust or its advisors that Wells Fargo 21 was increasing its fees. Id. ¶ 3.13.

22 The Trust went “live” on Principal Life’s system on May 25, 2021, but the 23 system immediately began to have “significant problems,” including failure to 1 timely and correctly deposit contributions into participant accounts, failure to 2 provide requested information on how the contribution correction was made or

3 funded, failure to attend Board meetings or provide timely responses to the Trust’s 4 “numerous questions and concerns,” and failure to provide the Board information it 5 needed “to complete its required annual audits.” Id. ¶ 3.14(a)-(h). 6 Ultimately, the Board terminated Principal’s services on May 1, 2022. Id. at 7 ¶ 3.15. The Trust’s new recordkeeper, Milliman, informed the Trust that Principal 8 had transferred the Trust’s reserve account in the amount of $300,000 to “the Trust

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Board of Trustees for the Alaska Carpenters Defined Contribution Trust Fund v. Principal Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-trustees-for-the-alaska-carpenters-defined-contribution-trust-fund-wawd-2023.