In Anderson v. DHL Retirement Pension Plan,1 the Ninth Circuit followed the First Circuit in finding that the elimination of the right to transfer an account balance from a defined contribution plan to a defined benefit plan does not violate the Employee Retirement Income Security Act of 1974's (ERISA) "anti-cutback" rule. However, the Ninth Circuit reached its conclusion on a different basis than did the First Circuit. ERISA's "Anti-Cutback" Ruleread more http://www.littler.com/publication-press/publication/ninth-circuit-joins-first-circuit-finding-elimination-pension-transfer