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Case 3:06-cv-00703-DRH-CJP Document 2 Filed 09/11/2006 Page 31 of 52Non-U.S. Developed Equity PoolU.S. Small Cap PoolU.S. Mid Cap PoolU.S. Large Cap PoolInternational Paper Company RetirementAccount – Non U.S. Developed EquityInternational Paper Company RetirementAccount – Small Cap PoolInternational Paper Company RetirementAccount – Mid Cap PoolInternational Paper Company RetirementAccount – Large Cap Pool125. Defendants’ operation and administration of the Plans in this manner encourages,and facilitates, the charging of excessive and unreasonable fees to the Plans.126. For example, the Defendants place Plan participants’ investments in the Plans’Large Cap Stock Fund in the “IPC Retirement Account – Large Cap Pool Master Trust” (the“Large Cap Master Trust”). The Large Cap Master Trust, in turn, holds various stocks andbonds directly, and holds nearly $1 billion in mutual funds, common collective trusts and otherpooled investments.127. These mutual funds and common collective trusts each charge investmentmanagement and administrative fees to Plan participants who have invested in the Large CapMaster Trust.128. As a result, each of the Plans’ participants in the Large Cap Master Trust pays:(A) Hard Dollar fees from his or her account to his or her respective Plan (for administration,auditing and recordkeeping); (B) a second layer of Hard Dollar fees from his or her account tothe Large Cap Master Trust (for administration, investment management and trustee services);and (C) a third layer of administrative and investment management fees charged by each mutualfund or common collective trust (as part of its expense ratio) contained within the Large CapMaster Trust.31