of the plan and a party in interest, but its conduct in causing the plan to pay the fee for its own benefit cannot trigger liability under ERISA Section 406(a) because this section deals with transactions between two distinct parties. Self-dealing transactions are addressed by ERISA Section 406(b), which we discuss herein. 4 . ERISA Section 408 provides certain exceptions to Section 406(a) prohibited transactions, 29 U.S.C. § 1108(b), but we need not address whether an exception applies here, as we do not find that the allegations describe a prohibited Section 406(a) transaction. 5 . For example, 406(b) has been found to prohibit transactions involving kick-backs to fiduciaries and self-negotiated loans. See, e.g., Nat'l Sec. Systems, Inc. v. Iola, 700 F.3d 65, 91-93 (3d Cir.2012) (<HOLDING>); Reich, 57 F.3d at 287, 289-290 (holding that
holding that a fiduciary who receives consideration in connection with a transaction involving plan assets violated section 406b and a nonfiduciary who facilitated that transaction could be liable holding that a service provider who accepted compensation prescribed by an armslength agreement was not a fiduciary for compensation purposes and therefore not liable under section 406b holding that relief for nonfiduciary liability only available where nonfiduciary is engaged in prohibited transaction under section 1106a1 recognizing step transaction doctrine whereby courts must consider all steps of transaction in light of entire transaction so that substance of transaction will control over form of each step holding testimony of officer and narcotics investigator who both witnessed drug transaction coupled with audio recording of transaction constituted sufficient corroboration