Cite as: 516 U. S. 489 (1996)
Thomas, J., dissenting
Second, the majority disregards any possible distinction between the respective roles of an ERISA trustee and an ERISA plan administrator that might counsel against the wholesale importation, into the statutory definition of plan administration, of common-law rules governing trustees. Under ERISA, a plan trustee is charged with "exclusive authority and discretion to manage and control the assets of the plan." § 403, 29 U. S. C. § 1103. Because the trustee's authority over plan assets is exclusive, a plan administrator under ERISA lacks the pre-eminent responsibility of the common-law trustee, namely, the management of the trust corpus. Thus, while it may be true under the common law that a trustee has such powers as are necessary to further the purposes of the trust, it does not automatically follow that the administrator of a benefits plan (who by definition lacks authority over plan assets) possesses all authority "necessary or appropriate" for carrying out the purposes of the plan. And the majority cites no authority for its assumption that an ERISA plan administrator is the functional equivalent of a common-law trustee. See ante, at 502, 505, 506.
At bottom, the majority's analysis is an exercise in question begging. If speculating about the company's financial stability or the security of plan benefits does not involve discretionary authority in plan administration, it is wholly irrelevant that providing such information "would seem" to be related to "carrying out an important plan purpose." Ante, at 502. That a communication was "about benefits," ante, at 501, or an activity was of a "plan-related nature," ante, at 503, is also of little significance unless the act involved plan administration. The whole purpose of § 3(21)(A)(iii) is to
fiduciaries, were authorized by the plan to perform this concededly fiduciary function. Like the common-law principle cited therein, the Central States dicta only becomes relevant once it is settled that a person is a fiduciary.
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