Does a deficiency in the administration of a pension trust constitute a "fiduciary administration deficiency"?

The courts have recognized a distinction for the purpose of 302 jurisdiction between "structural deficiencies," which establish jurisdiction, and "fiduciary administration deficiencies," which fail to establish jurisdiction over 302 trusts. ¹² This court has held that "jurisdiction is limited to so-called 'structural' deficiencies and does not extend to day-to-day fiduciary administration of welfare and pension funds". Wilson v. Board of Trustees, 564 F.2d 1299, 1300 (9 Cir. 1978).