“A string of cases in the Second Circuit Court of Appeals is putting ERISA claims administrators on notice that falling short of strict compliance with the DOL’s claims and appeal regulations may cost administrators a deferential standard of review…. Under the DOL’s final regulations governing disability benefit claims, if a plan fails to strictly comply with the new disability claims regulations, a claimant may file a civil suit under ERISA Section 502(a) immediately without exhausting the plan’s administrative remedies and the plan administrator’s benefit determination will be subject to de novo review…. The recent cases offer some lessons about the types of violations that may cause a plan administrator to lose its deferential standard of review.” [Trucker Huss]