Ninth Circuit Concludes Beneficiary Designation Form Not a Plan Document and Telephone Call Changed A Beneficiary

In Becker v. Mays-Williams, No. No. 13–35069 (9th Cir. Jan. 28, 2015), the Ninth Circuit was confronted with the issue of determining whether decedent Asa Williams, a long-time participant in his employer’s ERISA governed retirement savings plans, effectively changed his beneficiary designation from his ex-wife to his son from an earlier marriage. The Court concluded that to resolve the question, it would have to address a matter of first impression for the Ninth Circuit — whether beneficiary designation forms are plan documents.

To read this blog click here.