In addition to the five specific prohibited transactions involving parties in interest, ERISA prohibits fiduciaries from engaging in various acts of self-dealing or conflicts of interest. A fiduciary may not deal with plan assets in his own interest; act in a transaction involving a plan on behalf of a person whose interests are adverse to the interests of the plan, its participants or beneficiaries; or receive any consideration for his own personal account from any party dealing with the plan in connection with a transaction involving the plan's assets. Examples of fiduciary prohibited transactions under ERISA include:

1. A violation arose when persons acting as trustees for two different plans with different participants loaned money from one plan to the other. The court concluded that a borrower and a lender in the same transaction always have adverse interests. The court found a prohibited transaction without regard to the fairness of the terms of the loan to both sides. "Adverse" interests do not require that the fiduciary act in a manner that results in harm to the beneficiaries, but merely that parties have technically opposing interests.
2. A plan fiduciary violated ERISA by negotiating and causing a plan to invest in a life insurance company's group annuity contract, resulting in a 10% commission paid to his company on the investment, and by causing or permitting the plans to deposit money in certain banks that loaned him money.
3. Trustees violated ERISA by acting on both sides of a loan transaction where the trustees also served as trustees for the convalescent home borrowing money from the plan.
4. A union official and fiduciary for certain plans violated ERISA by remitting to the union monies that should have gone to the plans, by failing to remit sufficient amounts from the union accounts to the plans, and by failing to take steps to recover debts owed by the union to the plans. A fiduciary charged with such self-dealing bears a heavy burden. An investment manager receiving compensation from others involved in a transaction with the plan "either must prove by a preponderance of the evidence that the transaction in question fell within an exemption . . . or must prove by clear and convincing evidence that compensation it received was for services other than a transaction involving the assets of a plan."