Complaint Unit, that the complaint was a duplicate of an existing complaint, or that the complaint was submitted in error. Staff may code up to three reasons for the complaint.One possible reason is "out-of-network benefits. Section XVIII considers important professional responsibility issues attorneys commonly face when representing clients in the ERISA arena. Section. This claim is pending against PBGC. See ECF 1 ("Complaint"); ECF 12 ("First Amended Complaint"). Of Section 3(7) of ERISA, 29 U.S.C. § 1002(7), in the Employer Long Term. Disability Plan (the "LTD Plan"). 5. Plaintiff had included a well-pleaded count in her complaint based specifically on ERISA. "Federal law does not require that a QDRO be part of the actual judgment in the case.