4th Circuit Undoes Mandatory Class In ERISA Suit Over Passive Target-Date Funds

( March 11, 2026, 9:36 AM EDT) -- RICHMOND, Va. — Reversing and vacating certification of a mandatory class in a case challenging an employer’s decision to offer passively managed BlackRock LifePath Index target date funds (TDFs) in its retirement plan, the Fourth Circuit U.S. Court of Appeals on March 10 said the Employee Retirement Income Security Act claims at issue are “individualized” monetary ones that “cannot be joined in a mandatory class” and the lower court should not have “postponed the necessary rigorous analysis of commonality.”...