In 2014, Professor Colleen Medill testified before the ERISA Advisory Council on the topic of outsourcing employee benefit plan services. The United States Department of Labor released the Council's report in February 2015. In her testimony, Professor Medill discussed the lack of guidance from the Department or courts in regard to fiduciary allocation of trustee responsibilities and co-fiduciary liability and responsibilities.
A summary of the report is available at http://www.dol.gov/ebsa/publications/2014ACreport3.html.