How Opaque, Non-SEC-Regulated Target-Date Products Create Structural Conflicts, Hide Fees, Inflate Risks, and Enable Party-in-Interest Self-Dealing I. Introduction: The Quiet Rise of State-Regulated CITs in 401(k) Plans Over the last decade, Collective Investment Trusts (CITs)—private pooled vehicles chartered under state banking law—have displaced SEC-registered mutual funds as the dominant structure inside 401(k) Target Date Funds … Continue reading State-Regulated Collective Investment Trusts (CITs) as Vehicles for ERISA Prohibited Transactions