Indiana Funeral Directors Insurance Trust v. Benefit Actuaries, Inc.

EVANS, Circuit Judge.

Hoping to ensure affordable and comprehensive health insurance for their employees, a group of independent funeral directors who own small mortuaries in Indiana got together and created the Indiana Funeral Directors Insurance Trust. The Trust, formed in 1972, in turn administered a multiple insurance employer welfare arrangement (known as a MEWA) to provide health benefits to the employees. Five trustees administered the Trust, and they hired Benefit Actuaries — which despite its name does not employ any actuaries — to serve as the Trust’s third-party administrator,…