Finally, Shpiece notes, acknowledging that it may sound trite, "Companies should not lie." Under ERISA, plan fiduciaries are required to operate in the exclusive interests of plan participants and beneficiaries, he adds. They'll want to ask themselves if they are meeting this requirement if they authorize SPDs or other documents that are significantly incomplete.

Of course, the documents need to be written so that they're understandable. Still, Shpiece advises asking, "what would the participants want to know and how would they want to know it?"

For a sampling of the many law firm memos provided to corporate clients recently about the Cigna v. Amara opinion, here are those prepared by , by , and by .