Frequently Asked Questions

This page provides the answers to class members’ most frequently asked questions.

The information provided is in summary form and is not intended as a complete explanation of your rights. For full and complete information, you are directed to review carefully the Notices.

BASIC INFORMATION

Am I being sued?

No, you are not being sued.

What is this Class Action about?

In the Class Action, Class Representatives claim that, during the Class Period, Defendants violated the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, 29 U.S.C. §1001, et seq., with respect to their management, operation, and administration of the Plan, by causing the Plan to pay excessive fees for recordkeeping and administrative services and by retaining imprudent investment options in the Plan.

Defendants have denied and continue to deny the claims and contentions of the Class Representatives, that they are liable at all to the Class, and that the Class or the Plan have suffered any harm or damage for which Defendants could or should be held responsible. Defendants contend that they acted prudently and in keeping with their fiduciary responsibilities under ERISA, and in the best interests of the Plan’s participants.

How do I know if I am part of the Settlement Class?

You are part of the Class if you fit this definition:

“All participants and beneficiaries of the Liberty Mutual 401(k) Plan from April 10, 2014 through December 31, 2025, excluding the Defendants.”

Why is there a Settlement?

The Court has not reached a final decision as to the Class Representatives’ claims. Instead, the Class Representatives and Defendants have agreed to the Settlement. The Settlement is the product of extensive negotiations between Class Counsel and Defendants’ counsel. The parties to the Settlement have taken into account the uncertainty and risks of litigation and have concluded that it is desirable to settle on the terms and conditions set forth in the Settlement Agreement. The Class Representatives and Class Counsel, who are highly experienced in this kind of matter, believe that the Settlement is best for all Class Members.

What does the Settlement Provide?

Under the Settlement, a Qualified Settlement Account of $13,400,000 will be established to resolve the Class Action. The Net Settlement Amount is $13,400,000, plus applicable interest, minus any Administrative Expenses, taxes, tax expenses, Court-approved Attorneys’ Fees, Reimbursement of Expense, and Class Representatives’ Case Contribution Awards, and other approved expenses of the litigation.

The Net Settlement Amount will be allocated to Class Members according to a Plan of Allocation to be approved by the Court. Class Members fall into two categories: Current Participants and Former Participants.

If you had an account balance in the Plan as of December 31, 2025, you are considered a Current Participant. If you did not have an account balance in the Plan as of December 31, 2025, you are considered a Former Participant and you are required to submit a claim form.

How do I get a Settlement Benefit?

Whether you need to submit a claim form to receive your distribution depends on whether you are considered a “Current Participant” or a “Former Participant” (as defined in the previous FAQ).

If you are a Current Participant, you do not need to do anything to receive your share of the Settlement.

If you are a Former Participant, you need to submit a claim form to receive your share of the Settlement.

Allocations to Current Participants who are entitled to a distribution under the Plan of Allocation will be made into their existing account in the Plan. Former Participants who are entitled to a distribution will receive their distribution as a check mailed to the address they provided in the Claim Form and distributed directly to them individually or as a rollover to a qualified retirement account.

Do I have a lawyer in the case?

The Court has appointed the law firm Schlichter Bogard LLC, in St. Louis, Missouri, as Class Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense.

Can I exclude myself from this Settlement?

No. The Class was certified under Federal Rule of Civil Procedure 23(b)(1). Therefore, as a Class Member, you are bound by any judgments or orders that are entered in the Class Action for all claims that were asserted in the Class Action or are otherwise included as Released Claims under the Settlement.

How do I tell the court that I do not like the Settlement?

If you are a Class Member, you can tell the Court that you do not agree with the Settlement or some part of it. To object, you must send the Court a written statement that you object to the Settlement in Ahmed et al. v. Liberty Mutual Group, Inc. et al., No. 3:20-cv-30056-MGM (D. Mass.). Be sure to include your name, address, telephone number, signature, and a full explanation of why you object to the Settlement. Your written objection must be received by the Court no later than August 3, 2026. The Court’s address is United States District Court for the District of Massachusetts, 300 State Street, Springfield, MA 01105. Your written objection also must be mailed to the lawyers listed below, no later than August 3, 2026.

Please note that the Court’s Order Granting Preliminary Approval of this Settlement provides that any party to the litigation may, but is not required to, serve discovery requests, including requests for documents and notice of deposition not to exceed two hours in length, on any objector. Any responses to discovery, or any depositions, must be completed within ten days of the request being served to the objector.

CLASS COUNSEL
SCHLICHTER BOGARD LLC
Attn: Liberty Mutual 401(k) Plan Settlement
100 South Fourth Street, Suite 1200
St. Louis, MO 63102
Counsel for Plaintiffs and Class Representatives

DEFENDANTS’ COUNSEL
SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
James R. Carroll
Michael S. Hines
Mary E. Grinman
Nicole Pacheco
Nicholle P. Knapp
500 Boylston Street
Boston, MA 02116
Counsel for Defendants Liberty Mutual Group, Inc. and the 401(k) Plan Administrative Committee

When and where will the Court decide whether to approve the Settlement?

The Court will hold a Fairness Hearing over Zoom videoconference on September 2, 2026, at the United States District Court for the District of Massachusetts, 300 State Street, Springfield, MA 01105.

At the Fairness Hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are objections, the Court will consider them. After the Fairness Hearing, the Court will decide whether to give its final approval to the Settlement. The Court also will consider the petition for Class Counsel’s Attorneys’ Fees, Reimbursement of Expenses, and Class Representatives’ Case Contribution Awards.

Any changes to the date, time, or venue of the Fairness Hearing will be posted on this website.