When a $69 million settlement drops, it’s more than just a corporate write-off—it’s a signal flare in the murky world of fiduciary responsibility. UnitedHealth Group, one of the largest health care conglomerates in the country, has agreed to settle allegations that it mismanaged its own 401(k) plan, a move that impacts hundreds of thousands of participants and raises uncomfortable questions about just how well Fortune 100 companies understand—or choose to ignore—the obligations they owe their workers under ERISA.
The complaint, filed in 2021 and now resolved in 2024 after three years of litigation, centered on UnitedHealth’s use of the Wells Fargo Target Fund Suite—investments the plaintiffs allege were poorly managed and left participants with returns that didn’t match the risk. This wasn’t just a bad day in the market. This was, according to the allegations, systemic fiduciary failure, where decisions about plan menus may have been driven more by corporate convenience than participant outcomes.
The judge’s approval of the $69 million settlement might not be an admission of guilt, but it does speak volumes. You don’t stroke a check like that unless the risk of going to trial feels a whole lot worse. And for the 350,000 current and former employees who trusted their retirement savings to the company’s plan, it’s a bitter reminder that “do no harm” doesn’t always extend to the back office.
Charles Field, one of the lead attorneys on the case, put it plainly: ERISA’s fiduciary standards are “strict and exacting.” I’d go further—they are the backbone of retirement security in this country. When plan sponsors treat those duties as loose guidelines rather than legal obligations, people get hurt. Real people. The kind who work long hours, raise families, and count on these plans to deliver when it’s time to retire.
This case should resonate far beyond Minnesota. It’s a warning to every plan fiduciary, committee member, and corporate executive who views their retirement plan as a box to check or a line item to manage: ERISA doesn’t care how big your company is or how glossy your benefits brochure looks. It cares whether you’re putting participants first. Always.
If that sounds like a high bar, good. It’s supposed to be.
