Plan sponsors of employee benefit plans that are subject to ERISA are likely familiar with the requirements that ERISA imposes on plan fiduciaries. ERISA requires a plan fiduciary to “discharge his duties with respect to a plan solely in the interest of the participants and beneficiaries and for the exclusive purpose of: (i) providing benefits to participants and their beneficiaries (the “exclusive benefit rule”); and (ii) defraying reasonable expenses of administ