ERISA – ERISA Benefits Law

Five-Part Fiduciary Test Is Back: Update Financial Advisory Agreements Now

On March 20, 2026, the Department of Labor published a vacatur notice (FR Doc. 2026-05492, 91 FR 13503–13510) officially removing the 2024 Retirement Security Rule from the Code of Federal Regulations. The DOL’s Employee Benefits Security Administration has restored the longstanding 1975 five-part test for determining investment advice fiduciary status under ERISA and IRC § 4975, and has stated it has no plans to pursue new rulemaking on this topic. If you updated your advisory or service agreements to acknowledge an expanded fiduciary standard under the 2024 rule, those provisions now reference a legal standard that no longer exists. Agreements should be updated accordingly.

What Changed

The 2024 Retirement Security Rule would have significantly broadened the definition of an investment advice fiduciary. Under that rule, a single rollover recommendation—or any recommendation made in a position of trust—could have established ERISA fiduciary status, even without a continuing advisory relationship. Many advisers updated their service agreements, fiduciary acknowledgment letters, and client-facing disclosures to reflect this broader standard.

That rule was vacated by federal courts in Texas (Eastern District, March 12, 2026; Northern District, March 17, 2026). The DOL’s March 20 Federal Register notice formally removed the rule from the CFR. The operative standard is now, once again, the 1975 five-part test. This conclusion rests on the published vacatur notice (Final Rule) and EBSA’s confirmation that no replacement rulemaking is planned.

The Restored Five-Part Test

Under the reinstated 1975 regulation (29 CFR § 2510.3-21, as restored), a person is an investment advice fiduciary only if all five elements are met: (1) the person renders advice on the value of securities or other property, or makes investment recommendations; (2) on a regular basis; (3) pursuant to a mutual agreement, arrangement, or understanding; (4) that the advice will serve as a primary basis for investment decisions; and (5) that the advice will be individualized to the plan’s particular needs.

The practical significance for advisers: one-time rollover recommendations and isolated investment guidance generally do not satisfy the “regular basis” and “mutual agreement” prongs. Activities that the 2024 rule would have swept into fiduciary status—such as a single IRA rollover recommendation—may now fall outside fiduciary status under the restored test.

Why Your Agreements Need Attention

If your current service or advisory agreements contain language acknowledging fiduciary status for activities that only triggered fiduciary duties under the now-vacated 2024 rule, those contractual provisions may be creating obligations that the law no longer imposes. A contractual fiduciary acknowledgment can establish fiduciary status even when the underlying regulation does not require it. In other words, your agreement—not the regulation—becomes the source of your fiduciary duty, along with all the liability exposure that entails.

This is particularly relevant for advisers who provide rollover guidance, make one-time investment recommendations, or offer plan-level services that do not involve ongoing individualized advice to participants.

Recommended Action Items

Review all current advisory and service agreements. Identify any language added in 2024 or 2025 to comply with the Retirement Security Rule—particularly provisions acknowledging fiduciary status for rollover recommendations, one-time advice, or “positions of trust.”
Update fiduciary acknowledgment letters. If you revised acknowledgment letters to reflect the broader 2024 standard, revert to language consistent with the five-part test. Ensure fiduciary acknowledgments are limited to relationships that actually satisfy all five elements.
Revisit rollover documentation and disclosures. Rollover recommendation processes that were expanded to satisfy the 2024 rule’s requirements (including PTE 2020-02 compliance steps tied to the vacated rule) should be reassessed. Advisers may choose to retain best-practice documentation voluntarily, but should not contractually bind themselves to a standard the law no longer requires.
Coordinate with plan sponsor clients. Plan sponsors who engaged you under agreements reflecting the 2024 fiduciary standard should be informed of the reversion. Committee charters and investment policy statements referencing the vacated rule should also be updated.

Is Your 401(k) Plan Ready for Roth Catch-Ups in 2026?

Beginning January 1, 2026, “high earners” must make catch-up contributions on a Roth (after-tax) basis. The Treasury Department issued final regulations on this SECURE 2.0 change last month. Although the regulations are technically effective in 2027, plans must operate in good-faith compliance in 2026. Plan sponsors that permit catch-up contributions should understand these requirements to ensure smooth implementation in January.

Key Requirements

Participants age 50 or older in 2026 may make up to $8,000 in “catch-up contributions” (contributions above the general 401(k) limit, $24,500 in 2026) if permitted by the plan. Plans may increase the catch-up limit to $11,250 for participants turning 60 to 63 in 2026.

For 2026, employees whose 2025 FICA (W-2 Box 3) wages exceed $150,000 are considered “high earners.” Generally, only wages from a common law employer are considered for this purpose, but employers under common control or using a common paymaster may elect to aggregate wages. Notably, partners with only self-employment income and certain state/local government employees without FICA wages are thus not subject to the Roth-only rule.

Plan Document Requirements

Plans without a Roth feature must add one to continue offering catch-ups to high earners. If the plan allows Roth catch-ups for high-earners, it must make them available to all catch-up eligible participants. It may not require all catch-up contributions to be Roth, however.

Plan sponsors who are under common control or using a common paymaster should consider whether to elect the optional wage aggregation rule. If no election in made, wages are not aggregated.

Plans may adopt a “deemed Roth” rule under which catch-up contributions become Roth once statutory or plan limits are reached, provided high earners are given an “effective opportunity” to opt out—for example, by opting out of catch-up contributions or electing to have any deferrals that would otherwise be deemed Roth distributed to them. The regulations do define “effective opportunity,” but clear advance notice to high earners with a meaningful opportunity to opt out, possibly in an annual notice before the start of the year, would likely suffice.

Correction Options

The regulations provide three methods to correct pre-tax catch-up contributions that should have been Roth. A plan must apply the same method to all similarly situated participants for the year. The Form W-2 and in-plan Roth rollover correction methods are available only to plans that (a) include a deemed Roth election and (b) maintain written practices and procedures for Roth catch-ups.

Form W-2 Correction. If identified before the Form W-2 for the year of deferral is issued, transfer amounts to the participant’s Roth account and report the contributions as Roth on the Form W-2.
In-Plan Roth Rollover. Roll over the contributions to the participant’s Roth account and report the rollover on a Form 1099-R for the year of the rollover. A plan is not required to otherwise allow in-plan Roth rollovers to use this method.
Distribution. Distribute the excess pre-tax contributions and report the distribution on Form 1099-R.

The correction deadline generally extends to the last day of the year following the year of contribution to avoid a plan qualification failure, although earlier correction deadlines (for example, 402(g) or ADP) continue to apply. Earlier correction is therefore recommended.

No correction is required if the incorrect pre-tax amount is $250 or less or if FICA wages are determined to exceed the high earner threshold only after the correction deadline.

Action Items for Plan Sponsors

Review Plan Design. Plans that do not permit Roth contributions should consider adding them. High earners in plans that to not permit Roth contributions will not be able to make catch-up contributions beginning in 2026.
Consider Aggregation. Decide whether to adopt the optional wage aggregation rule for identifying high earners (for example, to simplify administration).
Evaluate a Deemed Roth Provision. A deemed Roth provision is required to use the Form W-2 or in-plan Roth rollover correction methods and reduces the need for affirmative elections, but requires clear communication and strong payroll and recordkeeping systems.
Communicate with Employees. Inform catch-up eligible participants who are high earners of the new Roth-only rule and their options, including opt-out rights under a deemed Roth provision.
Adopt Correction Procedures. To apply the W-2 or in-plan Roth rollover correction methods, the plan must (a) include a deemed Roth election (subject to opt out and with appropriate notice), and (b) establish policies and procedures relating to Roth catch-ups. Otherwise, the distribution correction method is required.
Implementation and Monitoring. Establish procedures to identify high earners using prior-year Form W-2 Box 3 wages and coordinate with services providers to ensure proper Roth designation.
Plan Amendments. Most plans will require amendments, but the deadline for SECURE 2.0 changes is generally December 31, 2026, even though operational compliance is required sooner.

Please reach out if you have questions or need help with these changes, including preparing Roth catch-up procedures or participant notices.

This alert is necessarily general. Consult with one of our attorneys or another qualified advisor if you have questions about your specific situation.

Department of Labor Adds Self-Correction to Voluntary Fiduciary Correction Program

The Department of Labor (DOL) published significant updates to its Voluntary Fiduciary Correction Program (VFCP) on January 15, 2025. These updates are designed to make it easier for employers and plan fiduciaries to avoid potential DOL civil enforcement and penalties if they voluntarily correct certain fiduciary breaches.

Key Changes – Addition of Self-Correction Features

The updated VFCP adds two new self correction categories, which better align the DOL’s VFCP with the IRS’s Employee Plans Compliance Resolution System (EPCRS), so that common issues subject to correction under both programs (to gain relief from both IRS and DOL enforcement) can be now be self-corrected. Previously, many failures that could be self-corrected under the IRS’s EPCRS required a formal VFCP application.

New Self-Correction Tool for Delinquent Contributions and Loan Payments

The most significant update to the VFCP is the introduction of a new self-correction tool, which employers and other plan officials can use to remedy delays in transmitting participant contributions and participant loan repayments to retirement plans. These are the most common fiduciary breaches requiring correction under both EPCRS and VFCP.

The VFCP imposes six broad requirements for self-correction of delinquent participant contributions or loan repayments involving retirement plans:

1. $1,000 Earnings Limit. The amount of Lost Earnings on the delinquent participant contributions or loan repayments must be $1,000 or less

2. 180 Limit. The delinquent participant contributions or loan repayments must have been remitted to the plan within 180 calendar days from the date of withholding from participants’ paychecks or receipt by the employer.

3. Lost Earnings Calculation Requirement. The Lost Earnings must be calculated using the DOL online calculator, starting from the “Date of Withholding or Receipt” (NOT from the earliest date the contributions could have been made to the plan)

4. SCC Notice Electronic Filing. The employer or other self-corrector must electronically file a Self-Correction Component Notice with the DOL, which must include:

the name and an email address for the self-corrector;
the plan name;
the plan sponsor’s nine-digit employer identification number (EIN);
the plan’s three-digit number (PN);
the Principal Amount;
the amount of Lost Earnings and the date paid to the plan;
the Loss Date (for purposes of the SCC, the Date(s) of Withholding or Receipt); and
the number of participants affected by the correction.

5. Penalty of Perjury Statement. A plan fiduciary with knowledge of the transaction that is being self-corrected and each Plan Official seeking relief under the program must sign a penalty of perjury statement.

6. Self-Correction Checklist and Document Retention. Self-correctors must prepare a SCC Retention Record Checklist and collect a list of documents, and provide the completed checklist and required documentation to the plan administrator. The checklist and documents include:

A brief statement explaining why the employer retained the participant contributions or loan repayments instead of timely forwarding such amounts to the plan;
Proof of payment, showing the actual date the plan received the corrective payment;
Lost Earnings printout from the DOL online Calculator;
A statement describing policies and procedures (if any) that the employer put into place to prevent future delinquencies of participant contributions or loan repayments;
A copy of the SCC Notice Acknowledgement and Summary page received from EBSA after electronic submission of the SCC notice; and
The required Penalty of Perjury statement

Also Note: Self-correction does not relieve plans from reporting delinquent participant contributions on the plan’s Form 5500 or Form 5500-SF, as applicable.

Self-Correction for Certain Participant Loan Failures Self-Corrected Under the Internal Revenue Service’s Employee Plans Compliance Resolution System (EPCRS.)

The updated VFCP also adds a new Self-Correction Component for participant loan failures, which allows self-correction of the following transactions, provided that they are eligible for, and have been self-corrected under, the IRS’s EPCRS:

Loans, the terms of which did not comply with plan and Code provisions concerning amount, duration, or level amortization, or loans that defaulted due to a failure to withhold loan repayments from the participant’s wages;
The failure to obtain spousal consent for a plan loan;
Loans that exceed the number permitted under the terms of the plan; and
Any eligible inadvertent failure relating to a participant loan that is self-corrected in accordance with EPCRS

Other VFCP Changes

The updated VFCP makes some additional changes, that will make it easier for employers to use the program, including

Expanded Scope of Eligible Transactions: The VFCP now covers a wider range of transactions that can be corrected. This includes transactions that were previously ineligible, such as certain types of excess contributions.

Clarification of Existing Corrections: The DOL has clarified the types of transactions that are already eligible for correction under the VFCP. This will help employers and plan officials determine whether they can take advantage of the program.

Simplified Procedures: The DOL has simplified the administrative and procedural requirements for using the VFCP. This will make it easier and less time-consuming for employers and plan officials to correct fiduciary breaches.

Updated Class Exemption: The DOL has amended the VFCP class exemption to reflect the changes to the program.

The updated VFCP goes into effect on March 17, 2025.

ERISA Benefits Law Recognized in 2025 Best Law Firms List

We are pleased to announce that ERISA Benefits Law has been recognized as a Tier 1 law firm for both Employee Benefits (ERISA) Law and Employment Law – Management in the 2025 edition of Best Law Firms®. We have received this honor for Employee Benefits (ERISA) Law every year since 2016 when we first opened, and for Employment Law – Management every year since 2021.

We are honored to be recognized for our service and appreciate the confidence our colleagues and peers have in us. We look forward to continuing to provide outstanding service and practical solutions to our clients’ complex questions.

Erwin Kratz and Kristi Hill Recognized in 2025 Best Lawyers and Ones to Watch in America Lists

We are delighted to share that Erwin Kratz and Kristi Hill have once again been recognized in the 2025 editions of The Best Lawyers in America® and the Best Lawyers: Ones to Watch® in America. They are grateful to their peers for selecting them to receive this honor. Please join us in congratulating them on this achievement!

Erwin Kratz and Kristi Hill Named to 2024 Southwest Super Lawyers and Rising Stars Lists

We are pleased to announce that Erwin Kratz and Kristi Hill have been selected to the 2024 Southwest Super Lawyers and Rising Stars lists for Employee Benefits. This is Erwin’s fourth consecutive year on the Super Lawyers list and Kristi’s third year on the Rising Stars list.

The Super Lawyers list is an exclusive list, recognizing no more than five percent of attorneys in the Southwest. The Rising Stars list recognizes no more than 2.5 percent of attorneys in the Southwest. Super Lawyers, part of Thomson Reuters, is a research-driven, peer-influenced rating service of outstanding lawyers who have attained a high degree of peer recognition and professional achievement. Attorneys are selected from more than 70 practice areas and all firm sizes.

Please join us in congratulating Erwin and Kristi on their selections.

Attorney Kristi Hill Receives Distinguished Legal Writing Award

ERISA Benefits Law is proud to announce that attorney Kristi Hill has been recognized as one of the nations finest law firm writers, by the Burton Awards, a national 501(c)(3) non-profit program, which is run in association with the Library of Congress. This award is made to a select group of 20 attorneys who demonstrate the highest standard of excellence in legal writing. Kristi won the award for her article Secure Act 2.0 – New and Enhanced Retirement Tools, which was published in the April 2023 edition of the Arizona Attorney magazine.

Kristi’s Law360 Distinguished Legal Writing Award will be presented by lead sponsor Law360, and co-sponsored by the American Bar Association, at an awards program to be held at the Library of Congress on May 20, 2024.

Congratulations, Kristi!

Employee Benefits Relief in the Year-End COVID-19 Stimulus Legislation

The Consolidated Appropriations Act, 2021 (H.R. 133) (the “Act”) was passed by both houses of Congress on December 21, 2020, and signed into law by the President on December 27, 2020. The Act is an incredible 5,593 pages long and contains both an omnibus spending bill to fund the government through September 30, 2021 and a COVID-19 stimulus package that provides approximately $900 billion in emergency relief to individuals and businesses.

The Act contains numerous provisions that impact employee benefit plans. The principal takeaways from the Act that plan sponsors must consider are summarized below. In contrast to the length of the Act itself, this alert is intended to provide a high level summary. Please reach out to us if you have specific questions about the Act.

Health and Welfare Plan Related Provisions

This is the largest health care legislative package since the Affordable Care Act and the Act includes almost a dozen new patient protections with quickly approaching effective dates, which will result in significant new regulation being issued in 2021.

FSA Flexibility

The Act provides for significant additional flexibility for both health care flexible spending arrangements (“FSA”) and dependent care FSAs. These provisions are optional, not required, and employers will need to amend their plans to provide the new rights, if they choose to offer them.

Carryover. Any unused funds in FSAs from a plan year ending in 2020 or 2021 may be carried over and used at any time in the next plan year. These carryovers will be allowed under rules similar to the existing carryover rules for health FSAs (but without the dollar limit on carryovers).

Grace Periods. FSAs with grace periods may extend those grace periods to up 12 months for plan years ending in 2020 or 2021. Normally, grace periods have a maximum 2 ½-month period.

Post-Termination Reimbursement. If an employee terminates participation during calendar year 2020 or 2021, FSAs may also reimburse for otherwise eligible expenses incurred through the end of that year (plus any grace period).

Dependent Care Post-Age 13 Coverage. For dependent care FSAs, if a dependent became too old to have their care expenses reimbursed (age 13) due to the pandemic, any unused funds may be used for the remainder of the plan year in which they aged out. Further, if any funds remain unused at that time, those funds can be used until the child turns 14.

Prospective Changes Permitted. For plan years ending in 2021, employees may prospectively change their FSA contributions without incurring a permitted election change event.

“No Surprise” Medical Billing Provisions

Under a section titled the “No Surprises Act,” the Act includes several provisions to regulate surprise medical billing from certain non network providers, air ambulances and for emergency services. These provisions concern bills from out-of-network providers requiring more money from the patient after the health plan has paid its part. This can happen in an emergency setting or where a patient goes into an in-network hospital, but is treated there by an out-of-network provider.

Generally, the Act provides that individuals covered by a group health plan or individual/group health insurance receiving non-emergency services at a network facility cannot be balance billed by a non-network provider, unless the non-network provider provides notice to the individual and the individual consents. An exception exists for “ancillary services”, such as anesthesiology, pathology, and radiology, and the Act also fleshes out associated details, such as payment timelines and dispute resolution processes.

The agencies are required to begin finalizing implementing regulations regarding the methodology for making payments by July 1, 2021, with the rest to come by December 31, 2021. These provisions become effective January 1, 2022.

These rules replace the current Affordable Care Act rules governing the payment of emergency services and apply to both grandfathered and non-grandfathered plans.

Additional Health Plan Provisions

ID Card Information. ID cards for group health plans (physical or electronic) must include, in clear writing, the deductible, out-of-pocket limits, and consumer assistance information.

Continuity of Care. Patients undergoing treatment for a serious and complex condition, who are pregnant, receiving inpatient care, scheduled for non-elective surgery or terminally ill must be notified if their provider leaves the network and given the opportunity to continue care (at an in-network rate) for 90 days.

Cost Comparison Tools. Plans and carriers will be required to offer cost comparison tools (via phone or the internet) starting with plan years beginning on or after January 1, 2022.

Gag Clauses Prohibited. “Gag” clauses will be prohibited. These clauses prevent health plans from sharing provider-specific reimbursements and information. Prohibiting these clauses facilitates the creation of the cost-comparison tools.

Provider Directories. Group health plans must update provider directories at least every 90 days and establish a system to respond to inquiries about the network status of a provider within one business day.

Mental Health Parity. Plans will be required to analyze the nonquantitative treatment limitations that they apply to mental health and substance use disorder benefits to show that the limitations are comparable to those that are used for medical/surgical benefits.

Retirement Plan Related Provisions

Partial Plan Terminations. The Act provides for temporary relief from the 100% vesting requirement for partial plan terminations caused by employee turnover under Code section 411(d)(3) if the turnover is due to COVID-19. A qualified plan will not incur a partial termination during any plan year which includes the period beginning on March 13, 2020, and ending on March 31, 2021, if the number of active participants covered by the plan on March 31, 2021, is at least 80% of the number of active participants covered by the plan on March 13, 2020.

Coronavirus-Related Distributions. The Act extends the COVID-19 in-service distribution relief under the CARES Act to money purchase pension plans.

Disaster Relief (Not Including COVID). The Act provides special disaster related distribution and loan rules (similar to prior natural disaster relief, including a distribution right, increase in loan limits, loan suspensions, etc.) for FEMA declared disasters (other than COVID-19) from January 1, 2020 through 60 days after enactment of the Act.

Consolidated Appropriations Act, 2021

DOL Final Rule Facilitates Retirement Plan Electronic Disclosures

The U.S. Department of Labor (DOL) published a final rule on May 27, 2020 that will allow employers to post retirement plan disclosures online or deliver them to employees by email, as a default. The DOL believes this will make it easier for employers to furnish retirement plan disclosures electronically, reducing administrative expenses and making disclosures more readily accessible and useful for employees.

Background

There are approximately 700,000 retirement plans covered by ERISA, covering approximately 137 million participants. ERISA-covered retirement plans must furnish multiple disclosures each year to participants and beneficiaries. The number of disclosures per year depends on the specific type of retirement plan, its features, and for defined benefit plans, the plan’s funding status.

Delivery methods for ERISA disclosures must be reasonably calculated to ensure that workers actually receive the disclosures. To deliver disclosures electronically, plan administrators previously had to rely on a regulatory safe harbor established by the DOL in 2002. See 29 CFR 2520.104b-1(c).

On August 31, 2018, the President issued Executive Order 13847, directing the DOL to review whether regulatory or other actions could be taken to make retirement plan disclosures more understandable and useful for participants and beneficiaries and to focus on reducing the costs and burdens that retirement plan disclosures impose on employers and others responsible for their production and distribution. The Order specifically emphasized that this review include an exploration of the potential for broader use of electronic delivery as a way to improve the effectiveness of the disclosures and to reduce their associated costs and burdens.

New Voluntary Safe Harbor

The new electronic disclosure rule establishes a new, voluntary safe harbor for retirement plan administrators who want to use electronic media, as a default, to furnish covered documents to covered individuals, rather than sending potentially large volumes of paper documents through the mail. The new safe harbor permits the following two optional methods for electronic delivery:

Website Posting. Plan administrators may post covered documents on a website if appropriate notification of internet availability is furnished to the electronic addresses of covered individuals.
Email Delivery. Alternatively, plan administrators may send covered documents directly to the electronic addresses of covered individuals, with the covered documents either in the body of the email or as an attachment to the email.

Retirement plan administrators who comply with the safe harbor will satisfy their statutory duty under ERISA to furnish covered documents to covered individuals. The safe harbor is limited in the following respects:

Limited Scope of the New Safe Harbor

The safe harbor is limited to retirement plan disclosures.

A plan administrator may use this safe harbor only for “covered individuals.” To be a covered individual, the person must be entitled under ERISA to receive covered documents and must have a valid electronic address (e.g., email address or smart phone number).

The new safe harbor does not supersede the 2002 safe harbor; the 2002 safe harbor remains in place as another option for plan administrators.

Protections for Plan Participants

The new safe harbor includes a variety of protections for covered individuals, including:
1. Right to Paper. Covered individuals can request paper copies of specific documents, or globally opt out of electronic delivery entirely, at any time, free of charge.

2. Initial Notification. Covered individuals must be furnished an initial notification, on paper, that the way they currently receive retirement plan disclosures (e.g., paper delivery in the US mail) is changing. The notice must inform them of the new electronic delivery method, the electronic address that will be used, and the right to opt out if they prefer paper disclosures, among other things. The notice must be given to them before the plan may use the new safe harbor.

3. Notifications of Internet Availability. Covered individuals generally must be furnished a notice of internet availability (NOIA) each time a new covered document is made available for review on the internet website.

To avoid “notice overload,” the final rule permits an annual NOIA to include information about multiple covered documents, instead of multiple NOIAs throughout the year.

The NOIA must briefly describe or identify the covered document that is being posted online, include an address or hyperlink to the website, and inform the covered individual of the right to request paper copies or to opt out of electronic delivery altogether.

The NOIA must be concise, understandable, and contain only specified information.

4. Website Retention. Covered documents must remain on an internet website until superseded by a subsequent version, but in no event for less than one year.

5. System Check for Invalid Electronic Addresses. Plan administrators must ensure that the electronic delivery system is designed to alert them if a participant’s electronic address is invalid or inoperable. In that case, the administrator must attempt to promptly cure the problem, or treat the participant as opting out of electronic delivery.

6. System Check at Termination of Employment. When someone leaves their job, the plan administrator must take steps to ensure the continued accuracy and operability of the person’s employer-provided electronic address.

Effective Date & Immediate Availability

The new safe harbor is effective July 27, 2020 (60 days after its publication in the Federal Register). However, the DOL, as an enforcement policy, will not take any enforcement action against a plan administrator that relies on this safe harbor before that date.

ERISA Benefits Law attorney Erwin Kratz was recently selected by his peers for inclusion in The Best Lawyers in America© 2020 in the practice area of Employee Benefits (ERISA) Law. Mr. Kratz has been continuously listed on The Best Lawyers in Americalist since 2010.

Since it was first published in 1983, Best Lawyers® has become universally regarded as the definitive guide to legal excellence. Best Lawyers lists are compiled based on an exhaustive peer-review evaluation. Lawyers are not required or allowed to pay a fee to be listed; therefore inclusion in Best Lawyers is considered a singular honor. Corporate Counsel magazine has called Best Lawyers “the most respected referral list of attorneys in practice.”

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