Hoye v. CHA General Services, Inc.

CourtDistrict Court, D. Massachusetts
DecidedFebruary 5, 2025
Docket1:23-cv-13238
StatusUnknown

This text of Hoye v. CHA General Services, Inc. (Hoye v. CHA General Services, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoye v. CHA General Services, Inc., (D. Mass. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS _______________________________________ ) SUSAN J. HOYE AND LEONARDO ) JIMENEZ, INDIVIDUALLY AND AS THE ) REPRESENTATIVES OF A CLASS OF ) SIMILARLY SITUATED PERSONS, AND ) ON BEHALF OF THE CAMBRIDGE ) HEALTH ALLIANCE PARTNERSHIP PLAN, ) ) Plaintiffs, ) ) v. ) Civil Action No. 23-13238-MJJ ) CHA GENERAL SERVICES, INC.; ) RETIREMENT PLAN COMMITTEE; AND ) JOHN AND JANE DOES 1-10, ) ) Defendants. ) _______________________________________)

MEMORANDUM OF DECISION

February 5, 2025

JOUN, D.J.

Susan J. Hoye (“Ms. Hoye”) and Leonardo Jimenez (“Mr. Jimenez”) have filed suit individually and on behalf of similarly situated persons and beneficiaries of The Cambridge Health Alliance Partnership Plan (the “Plan”) (collectively, “Plaintiffs”), against the Plan’s fiduciaries, CHA General Services, Inc. (“Cambridge Health”), Retirement Plan Committee, and John and Jane Does 1-10 (collectively, “Defendants”), alleging violations of the Employee Retirement Income Security Act of 1974 (“ERISA”). [Doc. No. 12 at 1; Id. at ¶ 47]. Plaintiffs are bringing this suit pursuant to ERISA §§ 409 and 502, 29 U.S.C. §§ 1109 and 1132. [Id. at ¶ 1]. The putative class that Plaintiffs seek to represent includes those who were participants in or beneficiaries of the Plan at any time between December 29, 2017, through the date of judgment (the “Class Period”), excluding any Defendants and their immediate family members. [Id. at ¶ 92]. Plaintiffs claim all Defendants breached their fiduciary duty of prudence; specifically, as the fiduciaries of the Plan, Defendants failed to ensure that participants have had appropriate

investment options and that the Plan’s service fees were reasonable. [Id. at 1; id. at ¶ 13]. Plaintiffs additionally allege that Cambridge Health failed to monitor other fiduciaries appointed to manage the Plan, as a “Retirement Plan Committee” was appointed in 2021 with some responsibility for oversight of the Plan. [Id. at ¶ 13]. On May 24, 2024, Defendants filed a Motion to Dismiss for failure to state a claim. [Doc. No. 28]. The matter was fully briefed. [Doc. Nos. 30, 32]. For the following reasons, Defendants’ motion is DENIED. I. BACKGROUND The below facts come from the Amended Complaint and are taken as true for purposes of evaluating Defendants’ Motion to Dismiss. See Ruivo v. Wells Fargo Bank, 766 F.3d 87, 90 (1st

Cir. 2014). In addition to the Amended Complaint, I also consider those documents “sufficiently referred to” or incorporated by it. Watterson v. Page, 987 F.2d 1, 3 (1st Cir. 1993). A. The Plan Ms. Hoye and Mr. Jimenez were or are employees of Cambridge Health who participated in the Plan—a 403(b) defined contribution retirement plan—during the Class Period. [Doc. No. 12 at ¶¶ 3, 17-18]. Upon hiring, an employee is immediately eligible to participate in the Plan and would make contributions through salary deferrals. [Id. at ¶ 34]. The Plan had net assets of around $242 million, $280 million, and $318 million at the end of 2019, 2020, and 2021, respectively. [Id. at ¶ 11]. The Plan had over 3,000 participants for each year of the Class Period. [Id. at ¶ 12 n.8]. In 2022, the Plan had 3,660 participants and over $280 million in assets available for benefits. [Id.]. Of these, at least $198 million were under management—making it among the top 3% of largest managed 403(b) plans.1 [Id. at ¶¶ 11-12]. A participant’s account is the sum of individual contributions plus the employer’s matching contributions, which start after

two years of service. [Id. at ¶¶ 31, 35]. Cambridge Health is the Plan Sponsor. [Id. at ¶ 22]. Cambridge Health is also the Plan Administrator, a named fiduciary under 29 U.S.C. § 1102(a) with the ultimate authority to control and manage the operation and administration of the Plan, and a functional fiduciary under 29 U.S.C. § 1002(21)(A) because it exercises discretionary authority or control regarding management and administration of the Plan and disposition of the Plan’s assets. [Id. at ¶¶ 22, 24]. As Plan Sponsor and Named Fiduciary, Cambridge Health has the power to appoint other fiduciaries of the Plan; it also has the corresponding fiduciary duty to monitor and supervise any appointees. [Id. at ¶¶ 25-26]. B. Recordkeeping Fees

Transamerica Financial Life Insurance Company (“Transamerica”), through Transamerica Retirement Solutions, provides the Plan’s recordkeeping services and has done so for the entirety of the Class Period. [Id. at ¶¶ 50, 73]. These administrative services include tracking participants’ account balances and sending participant communications. [Id.]. Numerous recordkeepers in the marketplace are able to provide the same services at very little cost. [Id.] The services provided by Transamerica are consistent with those provided by other recordkeepers. [Id.].

1 Large direct contribution plans with substantial management generally have a larger bargaining power in the market for services, fees, and expenses than other plans. [Doc. No. 12 at ¶ 12]. The Plan’s fiduciaries may choose whether recordkeeping is paid for by the Plan sponsor or from the Plan’s assets. [Id. at ¶ 52]. Here, recordkeeping was paid for from the Plan’s assets via revenue sharing. [Id. at ¶ 54]. Revenue sharing, under which investments within the plans make payments to the recordkeeper or to the plans directly for recordkeeping costs, may result in

hiding the true scope of fees from participants and fiduciaries. [Id. at ¶¶ 52-53]. During the Class Period, the Plan paid per-participant fees that exceeded the fees paid for similar services by similar-sized plans. [Id. at ¶ 55]. The publicly reported direct recordkeeping fees per participant were as follows (“Table 1”): Year Per-Participant Fee 2022 $63.20 2021 $77.83 2020 $70.13 2019 $71.20 2018 $71.61 2017 $93.03

[Id. at ¶ 57]. In addition to the direct recordkeeping fees above, Transamerica also received indirect revenue. [Id. at ¶ 55]. Fee disclosures provided to participants indicate even higher amounts paid for recordkeeping, noting that the Plan incurred general administrative fees for recordkeeping of up to 0.11% in 2022 and 0.17% in 2020, with a plan service fee of 0.22% deducted from the largest plan investment on a monthly basis. [Id. at ¶ 58]. Using these percentages, the fees were as follows: Year Per-Participant Fee 2022 $95.05 2021 $148.60 2020 $136.25 [Id. at ¶ 59]. NEPC, a consulting group, recently surveyed defined contribution plans and confirmed that larger plans are able to obtain lower recordkeeping fees. [Id. at ¶¶ 61-62]. NEPC sampled 207 plans, with the median plan having $805 million in assets and 4,506 participants. [Id. at ¶

61]. For plans with participants counts between 1,000 and 5,000, half paid between approximately $45 and approximately $70 per participant. [Id. at ¶ 62]. It is highly likely that the smaller plans accounted for the bulk of the higher-fee survey responses in this category and that larger plans within the range paid less. [Id.]. Plaintiffs also compared the Plan to similar ERISA plans discussed in Sellers v. Trustees of Coll., 647 F. Supp. 3d 14 (D. Mass. 2022) and Brown v. The MITRE Corp., No. 22-cv-10976, 2023 WL 238772 (D. Mass. Mar. 6, 2023). [Id. at ¶¶ 64- 65]. Recordkeepers may also earn ancillary revenue as a result of their relationships with plans. [Id.

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Hoye v. CHA General Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hoye-v-cha-general-services-inc-mad-2025.