Jonathan Bowen dot Boston

Tag: Suffolk Downs

  • The ERISA Lottery

    The ERISA Lottery

    The Complexity Defense

    If somebody tells me that something is too complex to explain, I ask one question… “What is the complexity protecting?”

    I’m not being hyperbolic; there’s an internet trend called “explain it to me like I’m five years old” for a reason.

    I can explain almost anything in this world in simpler terms, even when the explanation needs boundaries. The Employee Retirement Income Security Act of 1974 (ERISA) is not exempt from plain English. When the people exercising fiduciary authority over an ERISA-governed plan invoke complexity instead of explaining the underlying investment choices, the resulting money flows, or the supporting calculations, those decision makers have told me something; their complexity defense is hiding the answer.1

    That complexity defense can obfuscate the underlying mechanics of an employer’s pension or retirement plan. Those pension and retirement plan decision makers should use every tool available to educate the plan’s participants and beneficiaries, allay real fears over real issues, and promote conversation. The difference isn’t tone; it’s service.

    Within any ERISA-governed plan, some participants and beneficiaries will disagree with a plan’s decisions. Those people may be the most vocal and may never be satisfied. The plan can survive disagreement; the people running it still owe participants constant communication.

    Harvard, Mass General Brigham, and Private Equity

    Harvard Human Resources uses the heading “Prudent actions by Plan fiduciaries” within its statement of ERISA rights. Harvard Management Company separately reports that 41% of Harvard’s fiscal-year 2025 endowment was allocated to private equity. The same Harvard financial report puts only $961,000 of its $777.2 million pension portfolio in private equity — about 0.1% — while placing 82.4% in fixed-income securities.2

    Those are different pools, and that distinction is the point. Willis Towers Watson (WTW) studied 418 Fortune 1000 defined-benefit sponsors and reported 10.3% in all alternatives combined, not private equity alone. Within the 80 sponsors funded at 110% or more, private equity averaged 4.2%.3

    Mass General Brigham (MGB) reports a 32.9% private-equity allocation in its fiscal-year 2025 defined-benefit portfolio. The allocation-share comparison puts MGB’s figure at about 7.8 times WTW’s 4.2% cohort average; Harvard’s endowment figure is about 9.8 times that average. Harvard’s pension allocation is the counterpoint at about 0.1%; the contrast is not subtle.4

    Why does MGB’s reported private-equity share sit closer to Harvard’s perpetual endowment than to Harvard’s pension portfolio, and what did that concentration cost after management fees, performance allocations, fund expenses, custody, consulting, legal work, and administration?

    Harvard University and Mass General Brigham are independent nonprofit institutions, but they are institutionally intertwined. Massachusetts General Hospital and Brigham and Women’s Hospital — the two academic medical centers that founded MGB — are Harvard Medical School’s two largest teaching hospitals. MGB says three of its specialty hospitals are also affiliated with Harvard Medical School. The Ragon Institute formally connects Mass General Brigham, the Massachusetts Institute of Technology (MIT), and Harvard. Phillip “Terry” Ragon, InterSystems’ founder and chief executive officer, and Susan M. Ragon funded that collaboration through the Phillip T. and Susan M. Ragon Foundation. The Institute itself says its structure is designed to break down barriers between often-siloed academic disciplines. The institutional web is real; its existence, however, doesn’t merge Harvard’s endowment, Harvard’s pension portfolio, and MGB’s ERISA trust into one fiduciary pool.5

    An ERISA-governed plan should be explainable to the participants and beneficiaries who live within its consequences — doctors, nurses, and custodial employees alike. I’ve investigated the Consolidated Cash Balance Program of Mass General Brigham and Member Organizations, Plan 499, and the MGB ERISA Master Trust. The public trail can quickly turn into three-card monte.6

    The Pension Benefit Guaranty Corporation (PBGC) stands outside the financial machine I’m tracing; it becomes relevant only after a covered pension plan terminates without enough money; it is not a substitute for the autonomous solvency of the MGB ERISA Master Trust. PBGC’s 2023 Massachusetts table reported an average monthly benefit of $535 among 17,072 payees. PBGC’s historical study found that the 16% of vested participants whose benefits were reduced lost an average of 24% of benefit value.7

    If I can’t trace the money from one disclosed layer to the next, why should any participant be told that sophistication is the problem?

    The Numbers Game

    My analogy compares the cost layers surrounding an ERISA-governed plan to The Numbers Game, run by the Massachusetts State Lottery since 1976. The comparison gives me a way to explore fee layers. ERISA became law in 1974; the Massachusetts State Lottery launched The Numbers Game two years later.8

    The Numbers Game gives me a simple way to talk about layering from a gambler’s point of view. My mother played “the numbahs” for years. In fact, she ran the street number for a local East Boston bookie in the 1980s that was tied to the winning horses at Suffolk Downs, but that’s another story for another time.

    The Numbers Game has four slots; each slot can hold one of ten digits. I’ll pick 0209 as my “numbahs.” That exact four-digit number carries 1-in-10,000 odds.

    My analogy begins with $1 wagered on one draw; The Numbers Game rule puts 63%, or 63¢, into a pari-mutuel prize pool. Exact 4 carries 1-in-10,000 odds, so I scale that dollar to a hypothetical $10,000 benchmark: $6,300 enters the prize pool and $3,700 remains outside; the Lottery doesn’t promise one Exact 4 winner a fixed $6,300 payout or deduct a 37% “fee” from a $10,000 prize. My $10,000 figure is the before-cost benchmark for a fair $1 bet at 1-in-10,000 odds; its purpose is to make the first layer visible.9

    What happens to the other $3,700?

    Internal Costs and External Costs

    The $3,700 is not simply one internal fee, and the Massachusetts State Lottery Commission doesn’t keep all the money. The Commission’s fiscal-year 2025 all-games accounting says 18¢ of each sales dollar went to local aid, 6¢ to retailer commissions and bonuses, and 2¢ to administrative expenses; its 74¢ prize average is a different measure from The Numbers Game’s 63¢ draw pool. The Commission’s internal costs include wages, employee benefits, and operating expenses. The local-aid and retailer-commission allocations leave the Commission, but both remain part of my first dollar’s path. My analogy doesn’t need to pretend otherwise; its job is to show how one dollar can split before the player sees the result.10

    That 37% outside the prize pool jumps off the page. I could start running a similar game and return more money to bettors, but I’d risk criminal prosecution because I’m not a licensed operator. However, I’d be a wealthy bookie.11

    My exercise gives 0209 the win and gives me a hypothetical $6,300 share of the prize pool.

    If that is my only wager all year, I still have to report the winnings under federal and Massachusetts tax rules; I may choose to use a bank or an accountant, but neither is a required Lottery charge. Those are external costs and obligations. The federal and Massachusetts taxes don’t change the Lottery’s prize-pool math, but they can reduce the cash a winner keeps under the mattress. The professional and banking costs remain optional.12

    That hypothetical $10,000 never belonged to the winner; it was the before-cost benchmark behind a 1-in-10,000 chance. The game’s rule moves $6,300 of a hypothetical $10,000 draw pool into prizes before taxes and optional soft costs begin. My comparison follows the dollar through each visible layer.

    My hypothetical onion begins at $10,000, but The Numbers Game places only 63% into the prize pool before 0209 wins anything; the other 37% stays outside that pool, and taxes or optional costs can peel the winner’s share again.

    If the Lottery can explain that flow in plain English, why can’t an ERISA plan explain its own flows?

    Seven ERISA Categories

    Wall Street has its own potentially fraudulent practices; churning and front-running name two forms of trading abuse. The terms “parking” and “skimming” require separate definitions before either carries weight. I’ll explore those concepts elsewhere; ERISA-governed pension and retirement plans carry their own investigative categories…13

    1. Fee Layering and Opaque Compensation: Within a plan’s cost structure, direct or indirect fees, revenue sharing, or embedded costs may be unreasonable or insufficiently disclosed; before it becomes a crime, the question is civil.
    2. Self-Dealing and Conflicts of Interest: Whenever a fiduciary uses plan authority for personal benefit, represents an adverse interest, or leaves a material conflict unmanaged, self-dealing or conflict comes into view.
    3. Party-in-Interest and Affiliate Transactions: At the transaction level, a plan enters an arrangement with an employer, affiliate, or other party in interest without an applicable exemption or terms that protect participants.
    4. Imprudence and Failed Monitoring: In the monitoring process, fiduciaries select or retain managers without adequately testing fees, concentration, valuation, liquidity, or risk; even before fraud, that failure can be serious.
    5. Falsified Valuations and Required Records: Where someone knowingly inflates asset values, conceals losses, or falsifies a required record or filing, the issue becomes falsification.
    6. Kickbacks and Corrupt Procurement: Through a corrupt arrangement, someone offers, receives, or solicits consideration to influence a plan decision.
    7. Theft, Embezzlement, and Diversion: At its most direct, someone removes, misuses, or fails to remit plan money or participant contributions.14

    The clearest criminal pathways identified by the Employee Benefits Security Administration (EBSA) begin with the fifth item: knowingly falsifying values or required records, corruptly influencing a plan decision, or taking plan assets. EBSA identifies false statements or concealment, kickbacks, and theft or embezzlement as plan-related criminal offenses. My MGB investigation raises questions about total compensation, indirect-fee visibility, manager selection, conflicts and recusals, valuation, liquidity, and whether decisions served participants and beneficiaries alone; the public record does not establish self-dealing, false filings, kickbacks, theft or diversion, or criminal fraud, but much may be hidden from the public’s purview.15

    Inside the MGB Financial Machine

    The public record does not prove any crime in those seven investigative categories, but the breadth and depth of data points I’ve uncovered demand answers. I don’t need a criminal verdict before I ask whether Plan 499’s cost structure was reasonable, visible, and built for its participants. My first questions begin with receipts, not verdicts.

    My first receipt is the MGB ERISA Master Trust’s fiscal-year 2025 Form 5500.

    The MGB ERISA Master Trust’s Schedule H reports $13,275,441 in investment-advisory and investment-management fees; its Schedule C separately reports $11,423,581 across 16 named direct-compensation entries. Those figures are not interchangeable, and subtracting one from the other would manufacture “missing money” the filing doesn’t establish. The public record needs a reconciliation ledger before anybody can call either figure the total.16

    Which expenses sit in both schedules, which sit in only one, and which never reach either public line?

    My next layer of onion peeling is named but unpriced. The same Schedule C answer says eligible indirect compensation existed, and the filing identifies 82 disclosure parties without publishing their individual amounts. That answer does not mean every party received an extra payment from MGB; it does not mean the amounts were zero, either.17

    What was each provider’s total direct and indirect compensation after accounting for fund expenses, embedded charges, revenue sharing, float, and every offset or rebate?

    Mass General Brigham’s own documents place several internal actors inside the chain of authority. Plan 499’s summary plan description says the MGB Board of Directors selects professional investment managers, while MGB’s fiscal-year 2025 audit says the Board Investment Committee oversees pension assets through manager selection and asset allocation. The Plan Trustees are MGB’s Chief Financial Officer (CFO), Chief Investment Officer (CIO), and Chief Human Resources Officer (CHRO); the Mass General Brigham Investment Office also sits inside that chain, but the public record does not allocate every selection, monitoring, valuation, liquidity, and accounting duty among those actors.18

    Who recommended the manager, who approved the commitment, and who monitored the cost after the money moved?

    The names matter because the internal operating team, the related entity, and the employee-benefit trust are not the same structure. Mass General Brigham Investment Office is the staff function; MGB Pooled Investments LLC is a separate related legal entity formerly named Partners HealthCare System Pooled Investment Accounts LLC; MGB ERISA Master Trust is the employee-benefit trust holding Plan 499 assets. The public filings also report $6,530,023 in compensation to Partners HealthCare or Mass General Brigham under one employer identification number (EIN) across Plan 499 and Master Trust filings from fiscal years 2019 through 2022; that cross-layer stream raises questions about contract administration, allocation methods, recordkeeping, information management, and participant communication; it does not, however, prove duplicate billing, self-dealing, or an unreasonable charge although questions remain.19

    Outside that circle, the named providers become easier to see and harder to reconcile. Plan 499 reported $16,165,346 in direct compensation to Alight Solutions LLC for recordkeeping from fiscal years 2019 through 2024 and $6,117,234 to Willis Towers Watson US LLC or its predecessor for actuarial work over the same period. The Master Trust’s fiscal-year 2025 Schedule C reports 12 investment-manager entries totaling $10,463,816: Arrowstreet Capital received $5,781,013, Edgewood Management received $3,129,853, and NZS Capital received $1,046,096. State Street Bank and Trust received $486,340; Ropes & Gray and DLA Piper received a combined $262,041; PricewaterhouseCoopers received $211,384. Those reported payments do not, by themselves, establish fiduciary status, overpayment, or failure to serve participants.20

    MGB’s investment architecture creates another set of questions before any invoice appears; its audited defined-benefit portfolio reports 32.9% in private equity, 19.4% in diversifying equity, and 4.9% in real assets; those are manager-mandate labels, not a complete fee taxonomy. WTW calls private markets a “notoriously high-fee industry,” while Fidelity describes “2 and 20” as a common private-equity structure and the U.S. Government Accountability Office (GAO) documented in 2008 that a private-equity fund-of-funds manager typically charged about 1% of invested capital on top of underlying-fund fees. Those sources do not tell me MGB’s negotiated rates.21

    Which MGB vehicles, if any, charged management fees, carried interest, fund expenses, transaction costs, and administration, and which offsets or rebates reduced the bill?

    The legal form makes the look-through problem larger. MGB’s audit reports $10.2 billion, or 88.2% of the defined-benefit portfolio, in private partnerships and commingled funds valued using net asset value (NAV) as a practical expedient; its Schedule H separately reports $9.3 billion, or 79.9% of total assets, as partnership or joint-venture interests. Those figures come from different classification systems. The first is an audited valuation grouping, and the second is a Form 5500 legal-form category. The same audit reports $1.2 billion in unfunded commitments and says private partnerships may impose gates, lockups, and redemption restrictions.22

    When fund managers report values that MGB management evaluates, what independent testing verifies commitment pacing, valuation, fee accruals, liquidity, and net returns?

    The named recurrences bring the conflict question into view without answering it in detail. MGB’s current board includes Robert G. Atchinson, who holds managing-member roles in Adage Capital’s control chain; Bain Capital Chair John P. Connaughton; Bain Capital Senior Advisory Partner Paul B. Edgerley; Thrive Capital Partner and Executive Chairman Nitin Nohria; and Berkshire Partners Industry Advisor Carol Vallone. The Master Trust’s fiscal-year 2025 exposure to those four platforms totals $928.6 million, or about 8.0% of Trust assets. Adage, Bain Capital Credit, and Thrive also appear among the filing’s eligible-indirect-compensation disclosure parties, while no Berkshire provider match was located. The affiliations and exposures are documented; MGB’s public filings do not disclose the committee votes or recusal records.23

    The Participant’s Questions

    I don’t need a limited-partnership agreement on my kitchen table to ask some basic questions…

    • Which internal body authorized each cost?
    • Which MGB Board of Directors or Board Investment Committee members participated in each manager decision, and which members recused themselves?
    • Which affiliate or outside provider received the money, directly or indirectly, and for what service?
    • Which independent third party tested the fees, valuations, liquidity, conflicts, and net returns across those relationships?
    • What was the combined all-in cost after every layer?

    Which record shows that the costs were reasonable and served the doctors, nurses, researchers, custodial employees, and other Plan 499 participants whose retirement security depends on the answers?

    My Lottery analogy is a test of explanation, not an accusation of gambling, fraud, or a shared accounting system. A gambler wants to know the rules before putting cash down on a bet. The Massachusetts State Lottery publishes a 63% Numbers Game prize-pool rule and a separate all-games accounting that shows where a sales dollar goes; its labels are not MGB’s labels, but my explanatory test survives because the line between “investing” and “gambling” gets pretty thin when nobody can show me the bill.

    If the Lottery and ordinary tax rules can explain prize rules, local aid, retailer commissions, internal costs, and winner-side obligations in terms a player can understand, why should an ERISA plan holding billions of dollars provide less explanation?

    If I’m comparing The Numbers Game to the MGB ERISA Master Trust — the pool of assets at the center of Plan 499’s solvency — I’m left with one simple question.

    “Hey ma! What’s your favorite numbah?”

    Mass General Brigham can answer every question by placing the answers in one traceable line from authorization to recipient to service to total cost to net result; its public filings do not provide that line.

    If MGB’s answer is that the financial machine is too complex to explain, what is the complexity protecting?

    Source Notes

    1. The U.S. Department of Labor’s FAQs about Retirement Plans and ERISA, accessed July 20th, 2026, explains that ERISA sets minimum standards, requires covered plans to provide participant information, and assigns fiduciary accountability according to authority or control over plan management or assets. ↩︎
    2. Harvard Human Resources’ Summary Plan Descriptions: Retirement Programs, March 2025, uses the heading “Prudent actions by Plan fiduciaries.” Harvard University’s Financial Report — Fiscal Year 2025, October 2025, reports 41% of the endowment in private equity and separately reports $961,000 of private equity within $777.2 million of pension assets, or about 0.1%, with 82.4% of pension assets in fixed-income securities; the endowment and pension are different pools. ↩︎
    3. WTW’s 2023 Asset Allocations in Fortune 1000 Pension Plans, April 30th, 2025, covers 418 defined-benefit sponsors, reports an average 10.3% allocation to all alternatives combined, and reports 4.2% in private equity among the 80 sponsors funded at 110% or more. ↩︎
    4. Mass General Brigham’s Consolidated Audited Financial Statements — 2025 and 2024 reports a 32.9% private-equity allocation in its defined-benefit portfolio. Using Harvard University’s 41% endowment allocation and WTW’s 4.2% cohort average, 32.9 ÷ 4.2 rounds to 7.8 and 41 ÷ 4.2 rounds to 9.8; those are allocation-share ratios, not fee, risk, or performance comparisons. ↩︎
    5. Mass General Brigham’s Our Educational Commitment and Harvard Medical School’s Faculty of Medicine glossary document formal teaching-hospital affiliations. The Ragon Institute governance page and Mass General Brigham’s headquarters announcement identify Mass General Brigham, MIT, and Harvard as the institutional partners and document Phillip “Terry” Ragon and Susan M. Ragon’s support; those relationships do not merge the institutions or their investment pools. ↩︎
    6. Mass General Brigham’s Consolidated Cash Balance Program summary plan description, effective January 1st, 2022, states that Plan assets are held and invested in the MGB ERISA Master Trust. The U.S. Department of Labor’s Plan 499 Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026, gives the formal plan name as the Consolidated Cash Balance Program of Mass General Brigham and Member Organizations. ↩︎
    7. The Pension Benefit Guaranty Corporation’s Pension Data by Region and State, Table S-52, reports 17,072 Massachusetts payees, $110.3 million in 2023 payments, and a $535 average monthly pension; the state is based on participant residence, and the mean includes annuity and one-time payments. PBGC’s Single-Employer Guarantee Outcomes, May 2019, found that 16% of vested participants in 500 plans trusteed from 1988 through 2012 experienced reductions averaging 24% of benefit value; those historical results do not predict a Plan 499 outcome. ↩︎
    8. The Massachusetts Lottery’s Mass Lottery History dates the daily Numbers Game to 1976, and the Lottery’s current The Numbers Game page identifies the game used in the analogy. ↩︎
    9. The Massachusetts State Lottery’s The Numbers Game page says players may select up to four digits from 0 through 9, gives Exact 4 odds of 1 in 10,000, and places 63% of total bets for a draw into a pari-mutuel prize pool. The 63% rule applies to the draw pool; it does not promise one Exact 4 winner a fixed $6,300 payment. ↩︎
    10. The Massachusetts Lottery’s Supporting Communities page gives the fiscal-year 2025 all-games allocation as 74¢ to prizes, 18¢ to local aid, 6¢ to retailer commissions and bonuses, and 2¢ to administrative expenses. The Commonwealth’s fiscal-year 2025 State Lottery Commission budget separately identifies wages and salaries, employee benefits, and operating expenses; neither source is a Numbers Game-specific accounting of the 37% outside one draw’s prize pool. ↩︎
    11. Massachusetts General Laws chapter 271, section 7 addresses setting up or promoting a lottery for money or value and supplies the legal basis for the hypothetical private-lottery risk described in the article, subject to the statute’s terms and exceptions. ↩︎
    12. The Internal Revenue Service’s Topic No. 419, Gambling Income and Losses says lottery winnings are taxable and reportable, while the Massachusetts Department of Revenue’s Massachusetts Tax Information for Gambling and the Lottery addresses Massachusetts reporting and withholding. Those tax obligations arise on the winner’s side; neither source treats them as part of the Lottery’s prize-pool rule. ↩︎
    13. The U.S. Securities and Exchange Commission’s Investor.gov Churning entry defines excessive trading designed primarily to generate broker commissions, and the SEC’s Dallas-Based Trader With Front Running case describes trading ahead of large client orders to profit from expected price movement. These are securities-practice examples, not findings about MGB. ↩︎
    14. The Employee Benefits Security Administration’s Enforcement page identifies civil fiduciary, prohibited-transaction, valuation, custody, selection, and monitoring concerns, while its Fee Disclosure Failure Notice explains fiduciary duties concerning necessary services, reasonable costs, and direct and indirect compensation disclosures. The article’s seven-item list is an analytical synthesis of investigative categories, not an official EBSA seven-part taxonomy. ↩︎
    15. The Employee Benefits Security Administration’s Enforcement page separately identifies theft or embezzlement from an employee benefit plan, false statements or concealment in ERISA-required documents, and corrupt offers, acceptance, or solicitation affecting plan operations as criminal offenses. ↩︎
    16. The U.S. Department of Labor’s MGB ERISA Master Trust Form 5500 for the plan year ending September 30th, 2025, filed July 2nd, 2026, reports $13,275,441 in investment-advisory and investment-management fees on Schedule H and separately lists $11,423,581 across 16 direct-compensation entries on Schedule C. The two figures come from different reporting categories and do not establish one all-in total. ↩︎
    17. The U.S. Department of Labor’s 2024 Instructions for Form 5500 and EBSA’s Supplemental Schedule C FAQs explain the eligible-indirect-compensation disclosure route. The MGB ERISA Master Trust’s fiscal-year 2025 filing identifies 82 disclosure parties but does not publish an individual indirect-compensation amount for each party. ↩︎
    18. Mass General Brigham’s Consolidated Cash Balance Program summary plan description says the MGB Board of Directors selects professional investment managers and identifies the Chief Financial Officer, Chief Investment Officer, and Chief Human Resources Officer as Plan Trustees. MGB’s fiscal-year 2025 audited financial statements place pension-asset oversight with the Board Investment Committee through manager selection and asset allocation; the two public sources do not allocate every operating duty among those offices and the Mass General Brigham Investment Office. ↩︎
    19. The Internal Revenue Service’s Mass General Brigham Incorporated Form 990, Schedule R, tax year 2022, identifies MGB Pooled Investments LLC as a related investment partnership, and the entity’s Legal Entity Identifier record records Partners HealthCare System Pooled Investment Accounts LLC as the former legal name. The $6,530,023 figure is a derived sum of direct compensation reported to provider EIN 04-3294527 in Plan 499 filings for FY2019, FY2020, FY2021, and FY2022, together with Master Trust filings for FY2019, FY2020, FY2021, and FY2022. The aggregate identifies a cross-layer compensation stream; it does not establish duplicate billing or an unreasonable charge. ↩︎
    20. Plan 499’s Schedule C records for FY2019, FY2020, FY2021, FY2022, FY2023, and FY2024 support the reported six-year totals of $16,165,346 to Alight Solutions LLC and $6,117,234 to Willis Towers Watson US LLC or its predecessor. The MGB ERISA Master Trust’s fiscal-year 2025 Schedule C supports the investment-manager, custodian, legal, and audit figures; direct-compensation entries do not disclose every indirect or embedded cost. ↩︎
    21. MGB’s fiscal-year 2025 audit supplies the portfolio labels used in the article. WTW’s Private Market Solutions calls private markets a notoriously high-fee industry, Fidelity’s What Is Private Equity? describes “2 and 20” as a common structure, and the U.S. Government Accountability Office’s GAO-08-692 describes a private-equity fund-of-funds manager charging about 1% of invested capital on top of underlying-fund fees. Those sources describe published fee architecture; they do not disclose MGB’s negotiated rates. ↩︎
    22. MGB’s fiscal-year 2025 audited financial statements report $10.2 billion of the defined-benefit portfolio in private partnerships and commingled funds valued using net asset value, along with $1.2 billion in unfunded commitments and possible gates, lockups, or redemption restrictions. The MGB ERISA Master Trust’s fiscal-year 2025 Schedule H separately reports $9.3 billion as partnership or joint-venture interests; the audited valuation grouping and the Form 5500 legal-form category are not interchangeable. ↩︎
    23. Mass General Brigham’s Leadership and Governance page identifies Robert G. Atchinson, John P. Connaughton, Paul B. Edgerley, Nitin Nohria, and Carol Vallone as current directors. Official role records connect Atchinson to Adage Capital’s control chain, Connaughton and Edgerley to Bain Capital, Nohria to Thrive Capital, and Vallone to Berkshire Partners. The MGB ERISA Master Trust’s fiscal-year 2025 filing supports the derived $928.6 million exposure across those four platforms and identifies Adage, Bain Capital Credit, and Thrive among eligible-indirect-compensation disclosure parties; the cited records do not disclose committee votes or recusals. ↩︎