Congress passed the Employee Retirement Income Security Act of 1974 (ERISA) with the goal of "promoting increased participation in pension plans by increasing the security of future benefits." To achieve this goal, ERISA created a complex regulatory system complemented by civil- and criminal-enforcement provisions. Although Congress enacted ERISA to prevent frauds by plan trustees, trustees escape liability because courts narrowly interpret ERISA's statute of limitations for breaches of fiduciary duty-a limitations period so incoherent that it is "held together by chewing gum and baling wire." Normally, a plaintiff has three years from actual knowledge of the breach of fiduciary duty to bring suit, but the claim cannot be brought more than six years after the breach occurred. However, in the case of "fraud or concealment," plaintiffs receive a separate six-year time period starting from the date of discovery of the fiduciary's breach, regardless of when the breach actually occurred. Unfortunately, courts have failed to consider the nature of the fiduciary breach or the trust relationship when interpreting the "fraud or concealment" exception. This interpretive error has led courts to apply ERISA's statute of limitations restrictively. These courts' interpretations ignore the body of law upon which ERISA is based, the common law of trusts.