In Alfarone v. Bernie Wolff Construction Corp., 788 F.2d 76 (2d Cir.1986), a group of union-appointed trustees brought suit to recover benefit contributions and liquidated damages for work which allegedly should have been performed by certain union members under the collective bargaining agreement. Id. at 77. The trustees were evenly divided on whether there was a delinquency and on bringing suit. Id. In addition, the trust agreements mandated arbitration in the event of a deadlock, but the union-appointed trustees failed to pursue this administrative remedy. Id. Affirming a dismissal for lack of standing, the Court of Appeals for the Second Circuit stated: The limitation in the trust agreements on the powers and duties of less than a majority of the trustees under the instant plans is consistent with the power granted fiduciaries to bring a civil suit under ERISA. ERISA expressly requires that the acts of trustees be in accordance with trust agreements, 29 U.S.C. 1104(a)(1), and expressly contemplates joint administration of trust funds. 29 U.S.C. 1102(a)(1). ERISA does not abrogate the equal representation mandates of the Taft Hartley Act. 29 U.S.C. 1144(d).... Permitting the Union-appointed trustees to sue without first submitting the issue to arbitration would violate the firmly established federal policy favoring exhaustion of administrative remedies in ERISA cases.... Because the trustees have not exhausted their administrative remedies, their actions are premature and were properly dismissed. (Id. at 79.)