Yes. Under ERISA, a fiduciary must personally make good plan losses and restore to the plan any profits made by the fiduciary as a result of a breach of any fiduciary duties. The court may award other equitable or remedial relief deemed appropriate, including removal as plan fiduciary.

ERISA grants courts wide discretion to fashion legal and equitable remedies to make a plan whole and to protect the rights of participants and beneficiaries, including rescission of unlawful transactions and recovery of monetary loss (plus interest) to the plan. A court may order restitution for lost interest income from an imprudent loan and for excessive fees paid for services. A court may also order posting of a bond to insure the fund against future losses and to require installation of an investment manager. A constructive trust may be placed on property improperly received. Any recovery under ERISA §409 for a fiduciary breach redounds to the benefit of the plan itself.

Recovered losses may include the difference between the plan's actual earnings and what it would have earned absent the breach. In one instance, a court used the Standard & Poors 500 Composite Index as a surrogate for a prudent return forecast notwithstanding evidence of lower returns obtained by the plan from other investments. Another court accepted the return from a model portfolio proffered by an expert. Average plan portfolio return may also supply the pertinent standard.