Second Circuit Holds RMBS Trust Certificates—but Not Notes—Can Constitute ERISA Plan Assets

In Powell as Tr. of United Food & Com. Workers Union & Emps. Midwest Pension Fund v. Ocwen Fin. Corp., No. 23-999, —F.4th—-, 2026 WL 828159 (2d Cir. Mar. 26, 2026), the Second Circuit addressed a significant and frequently…