Mealey's (September 11, 2015, 10:10 AM EDT) -- SAN FRANCISCO — Specific terminology need not be used to meet the requirement of Employee Retirement Income Security Act Section 403(a) that “all assets of an employee benefits plan shall be held in trust by one or more trustees,” the Ninth Circuit U.S. Court of Appeals reiterated Aug. 28 after denying cross-petitions for rehearing (David Barboza v. California Association of Professional Firefighters, et al., Nos. 11-15472, 11-16024, 11-16081, 16082, 9th Cir.; 2015 U.S. App. LEXIS 15548)....