The terms of statutorily required plan summaries (or summaries of plan modifications) may not be enforced (under Section 502(a)(1)(B)) as the terms of the plan itself. The plan’s sponsor (e.g., the employer), like a trust’s settlor, creates the basic terms and conditions of the plan, executes a written instrument containing those terms and conditions, and provides in that instrument a procedure for making amendments. The plan’s administrator, a trustee-like fiduciary, manages the plan, follows its terms in doing so, and provides participants with the summary documents that describe the plan (and modifications) in readily understandable form. Here, the same entity (CIGNA) filled both roles, but that is not always the case. ERISA carefully distinguishes these roles, and we have no reason to believe that the statute intends to mix the responsibilities by giving the administrator the power to set plan terms indirectly by including them in the summary plan descriptions. At the same time, the reformation of the plan to conform with the administrator?s representations could be an appropriate equitable remedy under Section 502(a)(3): The power to reform contracts (as contrasted with the power to enforce contracts as written) is a traditional power of an equity court, not a court of law, and was used to prevent fraud. Second, the remedy essentially held CIGNA to what it had promised; namely, that the new plan would not take from its employees benefits they had already accrued. This aspect of the remedy resembles estoppel, a traditional equitable remedy. Third, the injunctions require the plan administrator to pay to already retired beneficiaries money owed them under the plan as reformed. But the fact that this relief takes the form of a money payment does not remove it from the category of traditionally equitable relief. Equity courts possessed the power to provide relief in the form of monetary “compensation” for a loss resulting from a trustee’s breach of duty, or to prevent the trustee’s unjust enrichment. Indeed, prior to the merger of law and equity this kind of monetary remedy against a trustee (sometimes called a “surcharge”) was exclusively equitable. Cigna Corp. v. Amara, 131 S.Ct. 1866 (2011).