This case study demonstrates how 24 months of strategic negotiation and expert defense successfully challenged DOL audit findings, reducing a $1.2 million penalty demand to just $100,000 for a global pizza chain.
Slashing $1.1 Million in DOL Penalties
Client: Global Pizza Chain
Global Pizza Chain, a multinational restaurant operator, sponsors a retirement savings plan valued at over $30 million for its employees. Following a 2022 U.S. Department of Labor (DOL) audit, the plan and its investment committee members faced allegations of fiduciary breach under ERISA, resulting in a demand for $1.2 million in “lost opportunity” costs. Hall Benefits Law (HBL) was retained to dispute these findings through prolonged negotiations. Over 24 months, HBL successfully challenged the DOL’s position, leading to a settlement of just $100,000—saving nearly $1.1 million, preserving the plan’s integrity, and setting a benchmark for defending ERISA audits.
THE CHALLENGE
The DOL audit concluded that the investment committee’s actions constituted a fiduciary breach, obligating the plan and fiduciaries to repay $1.2 million in alleged lost earnings. This stemmed from complex ERISA compliance issues, with the government holding firm on its assessment. Global Pizza Chain risked significant financial penalties, reputational damage, and potential disruptions to employee benefits if the full amount was enforced.
THE TURNING POINT
Faced with a seemingly unyielding DOL stance, Global Pizza Chain sought specialized ERISA litigation expertise to systematically dismantle the allegations. Without strategic intervention, the company would have been compelled to accept the full penalty, prompting the engagement of HBL to negotiate a resolution.
THE SOLUTION
HBL, led by partner Anne Tyler Hall, engaged in a methodical 24-month dispute process. They “chipped away” at the DOL’s claims by applying ERISA fiduciary standards and drawing on common law elements from prior successful breach defenses. This approach exposed deficiencies in the DOL’s evidence, ultimately compelling them to concede that the breach could not be fully substantiated.
Our Results
$1.1MM Savings
Reduced the $1.2 million demand to a $100,000 settlement, delivering nearly $1.1 million in direct savings for the plan and committee members.
Breach Allegations Overturned
Successfully argued against the fiduciary breach using ERISA and common law, forcing the DOL to abandon 90% of its position.
Protected Fiduciaries
Shielded individual investment committee members from personal liability and preserved the plan's tax-qualified status.
Efficient Resolution
Achieved a favorable outcome in January 2025, allowing Global Pizza Chain to refocus on business operations without ongoing regulatory overhang.
WHY IT MATTERS
ERISA audits can impose crippling penalties on retirement plans, but rigorous defense using regulatory expertise can turn the tide. This case illustrates the power of persistent negotiation and legal precedent in mitigating DOL claims, underscoring the need for proactive compliance and specialized counsel to protect plan sponsors from unfounded allegations.
ABOUT HBL
Hall Benefits Law (HBL) is a boutique ERISA and employee benefits law firm helping employers design and defend retirement and health plans. With offices nationwide, HBL advises on M&A benefits, ESOPs, executive compensation, and compliance, and drives savings and transparency through TPA and PBM negotiations. Firm clients have realized over $400MM+ in penalty abatements and multimillion-dollar annual plan savings.