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  • Title: Effect of delegation on standard of review. Geddes v. United Staffing, 469 F.3d 919 (10th Cir. 2006).
    Journal: Benefits Q; 2009; 25(1):64-6. PubMed ID: 19408446.
    Abstract:
    When an ERISA plan administrator delegates his discretionary authority to render plan benefit decisions to a third party, even one that is not a fiduciary, de novo review is not triggered when litigation arises. Rather, the standard for review is the "arbitrary and capricious"standard as set by the US. Supreme Court's 1989 decision in Firestone Tire and Rubber Co. v. Bruch.
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