Mealey's (January 12, 2021, 2:07 PM EST) -- SANTA ANA, Calif. — A payroll services company was not a fiduciary that had a role in any alleged negligent failure to obtain reinsurance coverage for a self-insured employee benefit plan, a California federal judge ruled Jan. 7, dismissing a third-party claim filed by the plan’s third-party administrators for relief under Employee Retirement Income Security Act....