Dissent by Judge PREGERSON.
WILLIAM A. NORRIS, Circuit Judge:
This appeal presents two questions:
(1) whether § 104(b)(4) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), 29 U.S.C. § 1024(b)(4), requires a plan administrator to furnish individual participants upon request with the names and addresses of other plan participants. We hold that it does not because such a list is not an “instrumente ] under which the plan is established or operated,” id,.;
(2) whether a plan administrator has a general fiduciary duty under ERISA § 404(a)(1)(A), 29 U.S.C. § 1104(a)(1)(A), to furnish individual participants with the names and addresses of other plan participants. We hold that it does not because this information is not related to “providing benefits to participants and their beneficiaries [or] defraying reasonable expenses of administering the plan,” the exclusive purposes for which the plan administrator may discharge its duties, id.
I
Background
Plaintiffs are three retirees (the “Retirees") who receive defined pension benefits from the Hughes Non-Bargaining Retirement Plan (the “Plan”). They are members of a self-appointed committee called the Hughes Salaried Retirees Action Committee, an organization that is also a named plaintiff. The Plan has some 60,000 participants, of whom some 10,000 are retirees.
The Retirees brought this action under ERISA to compel the Plan administrator (the “Administrator”) to furnish them with a list of the names and addresses of all retired participants of the Plan so the Retirees can “communicate with them about matters of concern to all retired participants regarding their pensions-” Am.Compl. ¶ 1. In particular, the Retirees say they want to communicate with other retirees about Hughes’s allegedly “unlawful use of excess Plan assets for the sole purpose of meeting Hughes’ funding obligations” and “to gain support for their efforts to obtain increased benefits through negotiation or if required, litigation, as well as to monitor the Plan.”1 Id. at ¶ 10.
The district court dismissed the complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. A three-judge panel of our court reversed.2 Hughes [689] Salaried Retirees Action Comm. v. Administrator of the Hughes Non-Bargaining Retirement Plan, 39 F.3d 1002 (9th Cir.1994). A majority of the active judges of the court voted to rehear the case en banc, 53 F.3d 1090 (9th Cir.1995), and we now vacate the panel’s opinion and affirm the judgment of the district court dismissing the complaint for failure to state a claim upon which relief may be granted.
II
ERISA § 104(b)(4)
We first consider the Retirees’ claim that the Administrator must furnish them with the names and addresses of retired Plan participants because this information is an “instrumentf ] under which the plan is established or operated” within the meaning of ERISA § 104(b)(4). Am.Compl. ¶¶ 18-20. Section 104(b)(4) provides:
The administrator shall, upon written request of any participant or beneficiary, furnish a copy of the latest updated summary plan description, plan description, and the latest annual report, any terminal report, the bargaining agreement, trust agreement, contract, or other instruments under which the plan is established or operated.' The administrator may make reasonable charge to cover the cost of furnishing such complete copies.
29 U.S.C. § 1024(b)(4) (emphasis added). According to the Retirees, the requested list of names and addresses falls within the statute because the Plan could not operate without it.
The district court, in rejecting the Retirees’ interpretation, explained:
Such an interpretation so strains the meaning of [§ 104(b)(4) ]’s language that it is impossible to conceive of any documents even tangentially related to an employee benefit plan which would not fall within its scope. Moreover, if there are limits, there is no way that [the Retirees’] reading of the statute would allow a plan administrator to know what they are. Such a result would subvert the intent of Congress to provide “detailed and uniform guidance” as to what information must be furnished to plan participants.
Order of Dismissal, filed July 9, 1991, at 6.
We agree with the district court that the Retirees’ interpretation of § 104(b)(4) would “strain the meaning” of the section. The district court reasoned:
Statutory construction of ERISA “‘must begin with the language employed by Congress and the assumption that the ordinary meaning of that language accurately expresses the legislative purpose.’ ” Metropolitan Life Ins. Co. v. Massachusetts, 471 U.S. 724, 740 [105 S.Ct. 2380, 2389, 85 L.Ed.2d 728] (1985) (quoting Park ‘N Fly, Inc. v. Dollar Park & Fly, Inc., 469 U.S. 189, 194 [105 S.Ct. 658, 661, 83 L.Ed.2d 582] (1985)). Following this approach, a list of plan participants cannot possibly be considered an instrument “under which the plan is established or operated.” The plain language of the statute limits the universe of documents falling within that phrase to documents similar in nature to those specifically identified, which describe the terms and conditions of the plan, as well as its administration and financial status. While this Court need not define precisely those documents falling under •that provision, it is clear that a list of plan participants does not. Obtaining such a list provides participants with absolutely no information whatsoever about the plan, and therefore ERISA neither requires nor contemplates its disclosure.
Id. at 627.
We agree with the reasoning of the district court. It is well established that ‘“words grouped in a list should be given related meaning.’ ” See, e.g., Massachusetts v. Morash, 490 U.S. 107, 114-15, 109 S.Ct. 1668, 1673, 104 L.Ed.2d 98 (1989) (quoting Schreiber v. Burlington Northern, Inc., 472 U.S. 1, 8, 105 S.Ct. 2458, 2462, 86 L.Ed.2d 1 (1985)) (interpreting “vacation benefits” in ERISA § 3(1) in light of other benefit plans listed in same section). The Supreme Court has recently characterized the documents [690] subject to § 104(b)(4)’s disclosure requirements as “governing plan documents.” Curtiss-Wright Corp. v. Schoonejongen, — U.S. -, -, 115 S.Ct. 1223, 1231, 131 L.Ed.2d 94 (1995). The relevant documents are those documents that provide individual participants with information about the plan and benefits. As the legislative history bears out, the documents contemplated by § 104(b)(4) are those that allow “the individual participant [to] know[ ] exactly where he stands with respect to the plan — what benefits he may be entitled to, what circumstances may preclude him from obtaining benefits, what procedures he must follow to obtain benefits, and who are the persons to whom the management and investment of his plan funds have been entrusted.” S.Rep. No. 127, 93d Cong., 2d Sess. (1974), reprinted in 1974 U.S.C.C.A.N. 4838, 4863.3
Unlike the documents specifically listed in § 104(b)(4) — -plan descriptions, annual and terminal reports, and bargaining and trust agreements — participants’ names and addresses provide no information about the plan or benefits. As the district court said so aptly, it would strain the meaning of “other instruments under which the plan is operated” to interpret it to include participant names and addresses. Cf. Werner v. Morgan Equip. Co., 15 Employee Benefits Cas. (BNA) 2295, 2301, 1992 WL 453355 (N.D.Cal.1992) (stock valuation report is an instrument under which a plan is established or operated when the plan measures benefits by the value of stock); Lee v. Dayton Power & Light Co., 604 F.Supp. 987, 1002 (S.D.Ohio 1985) (manual containing charts essential to the calculation of benefits is an instrument under which the plan is established or operated).
In reversing the district court, our original panel reasoned that § 104(b)(4) requires disclosure of all documents that are “critical to the operation of the plan.” Hughes, 39 F.3d at 1007. This test, however, admits of no limiting principle. For example, under this interpretation, an administrator of a medical plan would be required to disclose medical histories of participants in the plan, and the administrator of a pension or profit-sharing plan would be required to disclose wage records of participants, because the medical histories and wage records are crucial to the operation of the respective plans. It is fanciful to think that § 104(b)(4) was enacted to give plan participants an absolute right to obtain such information about other plan participants.
Indeed, under the original panel’s interpretation of § 104(b)(4), a plan administrator would be required to disclose virtually everything in its plan files upon request. The panel reasoned that the language “other instruments” is not limited to documents similar to the documents specifically listed in § 104(b)(4) because the statutory language “contains no such limitation, and we have found no other authority for limiting the statutory language this way.” Id. at 1008. In other words, according to the panel, § 104(b)(4) creates a generalized disclosure obligation subject only to articulated limits. See also id. at 1008 n. 8 (“The language of the statute does not contain the limitation the [691] Administrator urges us to adopt-”) (emphasis in original). We reject the reasoning of the panel. Under its interpretation of § 104(b)(4), it would be “impossible to conceive of any documents even tangentially related to an employee benefit plan which would not fall within [§ 104(b)(4) ]’s scope.” Order of Dismissal, filed July 9, 1991, at 16. Such a broad disclosure requirement, however, is not supported by either the language of the statute or its legislative history. Thus we decline to interpret § 104(b)(4) to require general disclosure, subject only to specified exceptions. On the contrary, § 104(b)(4) requires the disclosure of only the documents described with particularity and “other instruments” similar in nature.
In sum, we agree with the district court that “other instruments under which the plan is established or operated” is limited to documents that are similar in nature to the documents specifically listed in § 104(b)(4). A list of the names and addresses of plan participants is not such a document.4
Ill
ERISA § 404(a)(1)(A)
Retirees claim in the alternative that even if § 104(b)(4) does not require the Administrator to disclose the names and addresses, ERISA’s general fiduciary duty provision does. See ERISA § 404(a)(1)(A), 29 U.S.C. § 1104(a)(1)(A). Section 404(a) is a general standard of care provision that requires an ERISA plan fiduciary to “(1) ... discharge his duties ... solely in the interest of the participants and' beneficiaries and (A) for the exclusive purpose of (i) providing benefits ... and (ii) defraying reasonable expenses....”5
In their original complaint, the Retirees asserted three purposes for requesting the names and addresses of plan participants: communicating with other retirees about Hughes’s use of Plan assets; gaining support for their negotiation or litigation efforts to obtain increased benefits; and monitoring the Plan. Compl. ¶ 10. In dismissing the Retirees’ § 404(a)(1)(A) claim, the district court noted that ERISA already contains a comprehensive disclosure scheme (§ 104(b)(4)), and held that, “whatever the precise duties of a plan fiduciary under [§ 404(a)(1)(A)], those duties relate to and are limited to the obligations to provide benefits to plan participants and beneficiaries, to defray reasonable expenses in administering the plan, and to act with the requisite care and skill in conducting the affairs of employee benefit plans.” Order of Dismissal, filed July 9, 1991, at 5. The district court held that the Administrator had no duty to disclose the names and addresses of participants because that information was not related to any of these purposes. Id.
The Retirees filed a motion for reconsideration based on Acosta v. Pacific Enters., 950 F.2d 611 (9th Cir.1991), which was decided after the district court dismissed the Retirees’ complaint. In Acosta, a plan beneficiary requested a list of the names, addresses, and number of shares each plan participant owned in the employer corporation, id. at 614-15, for the transparent purpose of forming a shareholder coalition to elect corporate directors tending to favor liberal pension benefits. We held that § 404(a)(1)(A) did not [692] give rise to a duty to disclose the requested information because the right to vote was not a plan benefit and, thus, the plaintiff had not shown that “the disclosure requested ... [was] sufficiently related to the provision of benefits or the defrayment of expenses.” Id. at 619.
The district court denied the Retirees’ motion for reconsideration but granted them leave to amend their complaint. Tr. of Pro-eeed’gs, Dec. 14, 1992, at 11. In their amended complaint, the Retirees alleged that § 404(a)(1)(A) encompasses a duty to provide the participant list when sought “for purposes of communicating with the participants and beneficiaries of the Plan about matters concerning the provision of benefits and the administration of the plan.” Am.Compl. ¶ 15. They further alleged that the dispute at issue — whether ERISA requires the Plan to distribute all or part of the allegedly “surplus” assets to the beneficiaries in the form of increased pension benefits — “is a matter concerning the provision of benefits and administration of the Plan which entitles the plaintiffs to a copy of the list of Plan participants.” Id. at ¶ 16.
The district court again dismissed. Order of Dismissal, filed Feb. 9, 1993, at 8-9. The court quoted its 1991 Order of Dismissal, noting that the test it had used then — whether the request for information related to “ ‘providing] benefits to plan participants ... or defraying] reasonable expenses,’ ”— was the test “subsequently adopted in Acosta.” Id. at 3 (quoting Order of Dismissal, filed July 9, 1991). The court went on to say that “[Retirees’] inconsequential amendments likewise fail to bring their first amended complaint -within the test set forth in Acosta.” Id. at 5. The court reasoned that the Retirees were not seeking “information about the provision of benefits from the Plan,” id. at 6-7, but rather “access to others to solicit financial support for their related case in which they hope to obtain the Plan’s surplus assets.” Id. at 6. The district court concluded that § 404(a)(1)(A) did not require disclosure of the list because the list itself provides no information or access to information related to the provision of benefits or the defrayment of expenses. Id.
On appeal, the Retirees argue that the district court misapplied the Acosta test. They contend that the issue is not whether the information itself relates to the provision of benefits, as the district court had reasoned, but rather whether the Retirees’ asserted purpose in requesting the information relates to the provision of benefits. The Retirees maintain that their purpose relates to the provision of benefits because they seek the list in order to communicate with other retirees about joining together in an effort to obtain greater benefits.
Our three-judge panel reversed the district court. Hughes, 39 F.3d at 1007. According to the panel, the district court incorrectly “focused on the information the list provides rather than the Retirees’ purpose for seeking it.... [Under Acosta\ [o]nly the Retirees’ purpose for wanting the list, not the list itself, must relate to the provision of benefits.” Id. at 1006-07 (emphasis in original). Thus the panel agreed with the Retirees that the focus of the inquiry should not be the nature of the information but the Retirees’ asserted purpose. The panel concluded:
Access to the list could help the Retirees to secure what they perceive to be their rights under the Plan. This connection between the requested list and the “provision of benefits” satisfies our test in Acosta. Therefore, the Administrator had a fiduciary duty to disclose the list.
Id. at 1006 (emphasis added).
In using a subjective test — the Retirees’ asserted purpose for requesting the information — rather than an objective test— the nature of the requested information itself — the panel misread and misapplied Acosía. In Acosta, the inquiry was “whether the disclosure requested ... is sufficiently related to the provision of benefits or the defrayment of expenses.” Acosta, 950 F.2d at 619 (emphasis added). In using an objective test, Acosta is firmly grounded in the lan[693] guage of § 404(a)(1)(A), which provides that the fiduciary shall discharge his duties “for the exclusive purpose of: (i) providing benefits ... and (ii) defraying reasonable expenses. ...” 29 U.S.C. § 1104(a)(1)(A). We follow Acosta in holding that any disclosure duty that § 404(a)(1)(A) imposes on fiduciaries is limited to the disclosure of information that relates to the provision of benefits or the defrayment of expenses, which are the exclusive purposes for which an ERISA fiduciary may discharge its duties.
In focusing on the requestor’s asserted purpose, the panel fashioned a subjective test that is unworkable. There is no practical way of limiting the use of the information, once it is disclosed, to the purpose asserted by the requestor. Indeed, there is no way of assuring that the information will not be used by the requestor for other purposes, or, for that matter, will not be used by third parties who manage to obtain the information once it has been disclosed to a plan participant. In the context of requests under the Freedom of Information Act, the Supreme Court has said that the question of disclosure “cannot turn on the purposes for which the request for information is made.” United States Dep’t of Justice v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 771, 109 S.Ct. 1468, 1480, 103 L.Ed.2d 774 (1989). Instead, disclosure “must turn on the nature of the requested document....” Id. at 772, 109 S.Ct. at 1481. The logic of this rule is compelling for two reasons: (1) There is no practical way to restrict a requestor’s use of information to the purpose asserted in the request; and (2) there is no practical way of assuring that the information disclosed will not fall into the hands of others. In sum, we accept our Acosta panel’s objective test; we reject our Hughes panel’s subjective test.
We fail to see any basis for distinguishing this case from Acosta. Acosta reasoned that “benefit” refers to “a participant’s or beneficiary’s right to receive monies from the plan administrator or trustee.” Acosta, 950 F.2d at 619. If the right to solicit votes to elect directors who might vote for greater pension benefits is not a “benefit” for purposes of § 404(a)(1)(A), then neither is the right to solicit support for litigation that might result in greater pension benefits. In both Acosta and this case, the requested information about fellow participants does not relate to the provision of benefits or the defrayment of expenses. Accordingly, we hold that § 404(a)(1)(A) does not require a plan administrator to furnish individual participants with the names and addresses of other participants upon request.6 '
[694] The panel itself failed to identify a meaningful nexus between the information requested by the Retirees and the provision of benefits or defrayment of expenses. It held that the Acosta test was satisfied merely because the disclosure “could help” participants achieve some benefits-related purpose. Hughes, 39 F.3d at 1006. Surely this analysis stretches the Acosta test too far. As a practical matter, participants could always assert that a requested disclosure “could help” them achieve some benefits-related purpose by asserting — as Retirees do here— that the information requested “could help” participants monitor the administration of the plan by a self-appointed watch-dog committee.
In any case, since a participant list will not provide the Retirees with any information about the Plan, we fail to see how the list, or the access to other participants that it would facilitate, will aid in monitoring the Plan’s management. The Retirees’ argument that “[u]nless retirees can communicate with one another and organize to protect them rights under ERISA and under the plan, they will not be able to raise the support needed to enforce their rights against a well-funded pension plan,” Appellants’ Br. at 15, is unavailing. As this argument makes clear, the Retirees want to use the list to solicit financial support for future litigation. Congress has provided for recovery of costs and attorneys’ fees under ERISA § 502(g), 29 U.S.C. § 1132(g), and we find nothing in ERISA suggesting that Congress intended to help plan participants amass a litigation war chest by soliciting donations from other plan participants and beneficiaries.
In deciding that § 404(a)(1)(A) does not require disclosure of the names and addresses because they are not related to the provision of benefits, we avoid a question of statutory construction discussed, but not decided, in Acosta: Whether § 404(a)(1)(A), a general ERISA provision, may be interpreted to require the disclosure of documents that relate to the provision of benefits or the defrayment of expenses but are not documents required to be disclosed under § 104(b)(4), ERISA’s specific disclosure provision. In other words, may the general provision be interpreted in a way that expands the requirements of the specific provision? The Acosta panel speculated that a fiduciary’s duties under § 404(a)(1)(A) “may in some circumstances extend to additional disclosures” beyond those specified in ERISA § 104.7 Acosta, 950 F.2d at 618. -The Administrator argues that to interpret § 404(a)(1)(A) as requiring the disclosure of documents not required to be disclosed by § 104(b)(4) would effectively “supplant ERISA’s existing reporting and disclosure provisions.” Pet. for Reh’g at 13. We need not address this question of the relationship between § 104(b)(4) and § 404(a)(1)(A), however, because disclosure of the names and addresses of plan participants is not required by either § 104(b)(4) or § 404(a)(1)(A). The question would arise only if the documents were not disclosable under § 104(b)(4) but were arguably disclosable under § 404(a)(1)(A) because they were related to the provision of benefits or the defrayment of costs. Because we need not decide this question of statutory interpretation, we need not consider the concerns raised by the Administrator and the amici [695] about privacy8 and costs9 that would attend the disclosure of names and addresses of plan participants. Balancing such concerns on the one hand with the policy interests served by disclosure on the other is, of course, best left to Congress — particularly when the conflicting concerns and interests arise in an area of the law Congress has chosen to regulate with painstaking detail. See Nachman Corp. v. Pension Benefit Guaranty Corp., 446 U.S. 359, 361, 100 S.Ct. 1723, 1726, 64 L.Ed.2d 354 (1980) (ERISA is a “comprehensive and reticulated statute”).
In sum, we hold that ERISA § 404(a)(1)(A) does not require plan administrators to disclose the names and addresses of plan participants to other participants upon request because the disclosure would not provide information that is related to the provision of benefits or the defrayment of expenses.
CONCLUSION
The opinion of the original panel, 39 F.3d 1002, is VACATED, and the judgment of the district court dismissing the action for failure to state a claim under either ERISA § 104(b)(4) or ERISA § 404(a)(1)(A) is AFFIRMED.