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Article • July 1, 1998 • from P&J July, 1998
U.S. v. Glick, No. 97-1118, No. 1024 (2nd Cir.) (142 F.3d 520) (April 14, 1998) (Judge Donald P. Lay) by Case held that an agent with a contractually established commision rate is not, without further indicia, a fiduciary to an employee benefits plan for purposes of a § 2E5.1(b)(1) enhancement.