benefits.”) (quotations omitted); see generally 29 U.S.C. § 1022(a) (summary plan description “shall be sufficiently accurate and comprehensive to reasonably apprise such participants and beneficiaries of their rights and obligations under the plan”). ¶ 9. As one court has observed, however, “[t]he SPD’s important role in disclosure goes both ways: just as employees may rely on the terms of the plan as described in the SPD, so may a clear description in the SPD put them on notice of that plan’s terms.” Bilello, 607 F. Supp. 2d at 593 (emphasis added). Consistent with the trial court’s conclusion here, courts have thus held that claims predicated upon provisions in an employee retirement plan may accrue — and trigger the statute of hmitations — upon receipt of an SPD. See id. at 596-97 (<HOLDING>); Hirt v. Equitable Retirement Plan for
holding that the court of federal claims lacked jurisdiction over claims arising from the violation of a criminal statute holding appealable dismissal without prejudice where sixyear statute of limitation would not bar plaintiff from bringing a subsequent action but where certain statutory notice prerequisites to filing an action arising out of pesticide application did holding that claims arising from employers conversion from defined benefit to cash balance retirement plan aeerued with the distribution of the spds and were barred by the expiration of the sixyear statute of limitation since the plaintiff was on clear notice through spds issued more than six years before the suit holding that the united states court of federal claims lacked jurisdiction over claims arising from the violation of a criminal statute holding that an employees claim for breach of a letter agreement was preempted by erisa where the agreement did not specify the amount or other terms of the employees retirement benefits and the court would have to refer to the employers erisagoverned retirement plan to determine the employees retirement benefits and calculate the damages claimed