CourtListener opinion 11249459

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In the

 United States Court of Appeals
 For the Seventh Circuit
 ____________________
No. 25-1859
PACKAGING CORPORATION OF AMERICA THRIFT PLAN FOR
HOURLY EMPLOYEES,
 Plaintiff-Appellee,
 v.

DENA LANGDON,
 Defendant-Appellant,

 v.

CHRISTINA COPISKEY, as the Personal Representative of the Es-
tate of CARL W. KLEINFELDT and the Personal Representative
of the Estate of TERRY SCHOLZ,
 Defendant-Appellee.
 ____________________

 Appeal from the United States District Court for the
 Western District of Wisconsin.
 No. 3:23-cv-00663 — James D. Peterson, Chief Judge.
 ____________________

 ARGUED DECEMBER 10, 2025 — DECIDED FEBRUARY 2, 2026
 ____________________

 Before BRENNAN, Chief Judge, and LEE and KOLAR, Circuit
Judges.
 2 No. 25-1859

 LEE, Circuit Judge. Carl Kleinfeldt participated in a retire-
ment plan administered by his employer, the Packaging Cor-
poration of America ("PCA"). Kleinfeldt designated his wife,
Dená Langdon, as the primary beneficiary. After the couple
divorced in September 2022, however, Kleinfeldt sent a fax to
PCA's benefits center, requesting that Langdon be removed
as the primary beneficiary. But, when Kleinfeldt died in Jan-
uary 2023, Langdon was still listed as the primary beneficiary
of the account. This led to a dispute between Kleinfeldt's Es-
tate and Langdon over the funds in the account.
 Faced with this dispute, PCA initiated this interpleader ac-
tion against the Estate and Langdon and was subsequently
dismissed from the action. The two remaining parties then
filed cross-motions for summary judgment; however, while
they were pending, the district court determined that Klein-
feldt's sister, Terry Scholz, also had a potential interest as a
surviving contingent beneficiary. The court joined Scholz's
Estate (she had passed away after Kleinfeldt's death) as a nec-
essary party. Then, invoking the substantial compliance doc-
trine, the district court found that Kleinfeldt had successfully
removed Langdon as the beneficiary of the retirement account
and granted summary judgment sua sponte in favor of
Scholz's estate. Because Kleinfeldt did not satisfy the substan-
tial compliance test, we reverse.
 I
A. PCA's Retirement Benefit Plan
 PCA operates an employee retirement benefit plan, the
Thrift Plan for Hourly Employees ("Plan"), which is governed
by the Employee Retirement Income Security Act of 1974
("ERISA"). The Plan's governing documents provide the
 No. 25-1859 3

Committee with full discretion and authority to administer
the Plan, including interpreting and applying the terms and
conditions of the Plan.
 The plan documents also detail the method by which a
participant can designate beneficiaries to the individual's re-
tirement account. Moreover, participants are given the fol-
lowing instruction: "You should keep your beneficiary desig-
nation and your beneficiary's address up to date. To do so,
contact the PCA Benefits Center at [a designated phone num-
ber] or you can update your beneficiaries online."
 In the absence of a valid beneficiary or if the designated
party predeceases the participant, the Plan disburses the pro-
ceeds to the participant's spouse or estate, in that order. If a
beneficiary survives the participant but dies before receiving
distribution, the proceeds accrue to the beneficiary's estate.
B. Kleinfeldt
 The decedent, Carl Kleinfeldt, worked for PCA for ap-
proximately 32 years and participated in the company's Plan.
Kleinfeldt married Dená Langdon in August 2006. That same
year, Carl designated Langdon as the sole beneficiary of the
Plan and Kleinfeldt's sisters, Terry Scholz and Lisa Kottke, as
contingent beneficiaries. Kottke passed away in 2012.
 Kleinfeldt and Langdon divorced on September 21, 2022.
Pursuant to the divorce, Kleinfeldt and Langdon signed a
Qualified Domestic Relations Order in November 2022, which
allocated a portion of the proceeds in Kleinfeldt's retirement
account to Langdon. As such, the Plan segregated Langdon's
designated share from Kleinfeldt's account and disbursed the
funds to her; the remainder remained as part of Kleinfeldt's
retirement account.
 4 No. 25-1859

 Shortly after his divorce, on October 4, 2022, Kleinfeldt at-
tempted to remove Langdon as the primary beneficiary of his
retirement account. He directed his secretary to send a fax to
the PCA Benefits Center requesting the Plan to "remove [his]
former spouse" from his "health, vision[,] and dental insur-
ance and as a beneficiary from [his] 401k, pension[,] and life
insurance accounts." Exhibit C. Presumably in response, PCA
removed Langdon from Kleinfeldt's health, vision, and dental
insurance. As for the retirement account, PCA changed Lang-
don's status from "spouse" to "ex-spouse" but did not re-
move her as the primary beneficiary. Kleinfeldt died on Janu-
ary 16, 2023.
C. Procedural History
 Following Kleinfeldt's death, PCA initially notified Lang-
don that it intended to distribute the funds in the retirement
account to her as the primary beneficiary. Around this time,
the Kleinfeldt Estate, represented by Scholz, also inquired
into the account and submitted a Claim Initiation Form for the
entirety of the proceeds; PCA denied this claim on May 18,
2023. A few days later, the Kleinfeldt Estate appealed PCA's
denial of its claim, arguing that the October 4, 2022 fax had
effectively removed Langdon as the primary beneficiary.
Meanwhile, to preserve her own claim, Langdon submitted a
Claim Initiation Form as well, demanding that the funds be
distributed to her.
 Faced with competing claims, the Plan filed an inter-
pleader action under Federal Rule of Civil Procedure 22 in the
district court and deposited the funds into the court's registry.
PCA and the Plan were then dismissed from the action. And,
as the litigation proceeded, the district court determined that,
at the time of Kleinfeldt's death, Scholz also may have had a
 No. 25-1859 5

potential claim as a contingent beneficiary. And so, the district
court added her estate (Scholz passed away during the pen-
dency of the lawsuit) as a defendant under Rule 19(a).
 After discovery, Langdon and the Kleinfeldt Estate filed
cross-motions for summary judgment. But, rather than grant-
ing one or the other, the district court denied both and instead
granted summary judgment sua sponte to Scholz's estate. In
short, the district court concluded that Kleinfeldt's actions of
October 4 constituted substantial compliance with the terms
of the Plan and, thus, were sufficient to remove Langdon as
the primary beneficiary, which left Scholz as the contingent
beneficiary. Langdon appeals.
 II
 We review a district court's summary judgment decision
de novo. Metro. Life Ins. Co. v. Johnson, 297 F.3d 558, 561 (7th
Cir. 2002) (citation omitted). Summary judgment is appropri-
ate where the record evidence shows "that there is no genuine
issue as to any material fact and that the movant is entitled to
judgment as a matter of law." Fed. R. Civ. P. 56(a); see also Ce-
lotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). "With cross-mo-
tions, our review of the record requires that we construe all
inferences in favor of the party against whom the motion un-
der consideration is made." Hendricks-Robinson v. Excel Corp.,
154 F.3d 685, 692 (7th Cir. 1998). In this case, because Langdon
appeals the denial of her summary judgment motion, we view
the facts in the light most favorable to her. Before proceeding
to the merits, however, we must address two threshold ques-
tions raised by the parties.
 6 No. 25-1859

A. Standard of Review
 First, there is some question as to whether the Plan's initial
decision to distribute the retirement funds to Langdon means
we should apply the arbitrary and capricious standard when
deciding the merits. Langdon answers in the affirmative, cit-
ing to Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115
(1989), and Butler v. Encyclopedia Britannica, Inc., 41 F.3d 285,
288 (7th Cir. 1994). But, in those cases, the plan administrator
actually determined eligibility, either by determining the ben-
eficiary and distributing the funds or by denying benefits out-
right. Here, as the Estate notes, the Plan threw its arms in the
air and filed this interpleader action. Because the plan admin-
istrator here did not exercise its discretion to make a final de-
termination as to the proper beneficiary, the applicability of
the arbitrary and capricious standard is in some doubt. 1
 This question should not detain us long, however, for both
parties agree that the district court's determination that Klein-
feldt satisfied the substantial compliance standard is a ques-
tion of law that we review de novo. See Sellers v. Zurich Am. Ins.
Co., 627 F.3d 627, 631 (7th Cir. 2010) (citation modified)
("Where … the denial of benefits determination is based on
an interpretation of law, we apply a de novo standard of re-
view."); Meyer v. Duluth Bldg. Trades Welfare Fund, 299 F.3d

 1 It is true that the Plan initially designated Langdon as the beneficiary
and notified her that the totality of retirement funds was placed into a sep-
arate account in her name on February 16. But once this dispute arose, the
Plan froze those funds before Langdon could access them. Langdon also
points to the Plan's May 18, 2023, letter denying the Estate's claim as evi-
dence that the Plan made a final determination. But the letter itself indi-
cated that it was not a final decision, stating that "th[e] claim denial will
become final" unless the Estate appealed, which it did.
 No. 25-1859 7

686, 689 (8th Cir. 2002) (citation modified) ("[W]here a plan's
decision to deny benefits is based on its construction of exist-
ing law, the plan's interpretation of a controlling principle of
law is reviewed de novo.").
 The Eighth Circuit's decision in Alliant Techsystems, Inc. v.
Marks, 465 F.3d 864, 868 (8th Cir. 2006), does not counsel a
contrary conclusion. Like here, the plan administrator in that
case made an initial beneficiary determination but initiated an
interpleader action when another potential beneficiary ap-
pealed. Because the plan provided the administrator with dis-
cretion to "determine all factual and legal questions under the
Plan" based on the "terms of the Plan," the Eighth Circuit con-
cluded that the Plan's initial determination was entitled to
"deference under the abuse of discretion standard." Id. at 868–
70. Notably, however, the court acknowledged that "[j]udicial
review is de novo … where an administrator did not exercise
the discretion granted to it, … and for issues that were within
the administrator's discretion but on which the administrator
failed to render a decision." Id. at 868 (citations omitted).
 Unlike the plan in Alliant Techsystems, the Plan here does
not bestow upon the administrator the discretion over "legal
questions under the Plan." Nor did PCA make any determi-
nation as to whether Kleinfeldt met the substantial compli-
ance test. In fact, when the Kleinfeldt Estate submitted its
claim to the Plan, it argued primarily that, due to the divorce
decree, Wisconsin law revoked any interest Langdon may
have had in the remaining retirement funds. The Plan denied
 8 No. 25-1859

the claim but allowed the Estate to appeal. 2 It was for the first
time on appeal that the Kleinfeldt Estate raised an argument
that sounded in substantial compliance, contending that
Kleinfeldt had "properly and legally communicated his inten-
tion to have his ex-spouse removed as a beneficiary entirely
from the plan." But, rather than addressing this issue, the Plan
filed the interpleader action. Thus, even under the framework
adopted by the Eighth Circuit in Alliant Techsystems, we
would review the question of substantial compliance de novo.
B. Substantial Compliance Doctrine Post-Kennedy
 Next, Langdon argues that the Supreme Court in Kennedy
v. Plan Administrator for DuPont Savings & Investment Plan, 555
U.S. 285 (2009) vitiated the federal common law doctrine of
substantial compliance. As we have observed, ERISA's statu-
tory scheme "does not contain any provisions governing dis-
putes between claimants to plan proceeds, or addressing
whether an insured has effectively changed a beneficiary des-
ignation." Johnson, 297 F.3d at 564. Consequently, in situations
like this, where ERISA preempts state law but is silent on a
controlling issue, the Supreme Court has recognized the need
for a body of federal common law based on state-law princi-
ples. See Bruch, 489 U.S. at 110 (citation modified) ("We have
held that courts are to develop a federal common law of rights
and obligations under ERISA-regulated plans."); see also
Thomason v. Aetna Life Ins. Co., 9 F.3d 645, 647 (7th Cir. 1993)

 2 The Plan's denial letter states that "the Plan's procedures do not al-
low a Plan beneficiary designation to be changed based on a faxed re-
quest." It also states that Kleinfeldt "did not take the actions necessary to
change his Plan beneficiary prior to his death." The Plan did not address
the substantial compliance doctrine.
 No. 25-1859 9

(explaining that where ERISA is silent, courts must develop
new federal common law and may use state common law as
a basis, to the extent that state law stays consistent with con-
gressional policy concerns).
 Rooted in federal common law, we have long recognized
the doctrine of substantial compliance in ERISA cases. See,
e.g., Johnson, 297 F.3d at 567–68 (citation modified) (adopting
the common-law rule of substantial compliance for change-
of-beneficiary forms for ERISA-governed life insurance
plans); Davis v. Combes, 294 F.3d 931, 940 (7th Cir. 2002) (cita-
tion modified) ("The concept of substantial compliance is part
of the body of federal common law that the courts have de-
veloped for issues on which ERISA does not speak directly.").
This is so, even though we have "consistently refused to cre-
ate federal common law remedies or implied causes of action
under ERISA." Bauwens v. Revcon Tech. Grp., Inc., 935 F.3d 534,
538 (7th Cir. 2019). This then leads us to Kennedy.
 Kennedy involved an employee who had designated his
wife as the sole beneficiary of his ERISA employee pension
plan. 555 U.S. at 289. The couple divorced, and the wife
agreed as part of the divorce decree to waive her interest in
her husband's pension plan. Id. The husband, however, died
before removing his ex-wife as the designated beneficiary. Id.
His estate then requested that the plan administrator disburse
the funds to the estate based on the divorce decree, but the
plan administrator refused, citing the husband's original des-
ignation form, and provided the funds to the ex-wife. Id. at
290. At that point, the estate sued the plan administrator, ar-
guing that the ex-wife had waived her rights to the retirement
funds as a matter of federal common law.
 10 No. 25-1859

 The question before the Supreme Court was "whether a
beneficiary's federal common law waiver of plan benefits is
effective where that waiver is inconsistent with the plan doc-
uments." Id. at 292. The Court answered in two steps. First, it
found that the ex-wife's waiver was not barred by ERISA's
anti-alienation provision, 29 U.S.C. § 1056(d)(1). Id. at 292–
297. More relevant for our purposes, however, the Supreme
Court also held that the plan administrator was not obligated
to honor the waiver because it was entitled to rely on the plan
documents, which directed disbursement of the funds in ac-
cordance with the deceased's beneficiary designation form
(which the husband had failed to change).
 A plan administrator is "obliged to act in accordance with
the documents and instruments governing the plan," the Su-
preme Court observed, "and ERISA provides no exemption
from this duty when it comes time to pay benefits." Id. at 300
(citation modified). "The point is that by giving a plan partic-
ipant a clear set of instructions for making his own instruc-
tions clear," the Court continued, "ERISA forecloses any jus-
tification for enquiries into nice expressions of intent, in favor
of the virtues of adhering to an uncomplicated rule." Id. at
301. Such a rule eliminates the need for "a plan administrator
to figure out whether a claimed federal common law waiver
was knowing and voluntary, whether its language addressed
the particular benefits at issue, and so forth, on into factually
complex and subjective determinations." Id. at 302; see In re
Radcliffe, 563 F.3d 627, 633 (7th Cir. 2009) ("Under Kennedy, the
administrator is obligated to pay the benefits in conformity
with plan documents without resort to external docu-
ments[.]"). And this, in turn, promotes "simple administra-
tion, avoiding double liability [for plan administrators], and
ensuring that beneficiaries get what's coming quickly,
 No. 25-1859 11

without the folderol essential under less-certain rules." 555
U.S. at 301 (quoting Fox Valley & Vicinity Constr. Workers Pen-
sion Fund v. Brown, 897 F.2d 275, 283 (7th Cir. 1990) (Easter-
brook, J., dissenting)). As Langdon sees it, the same reasoning
invalidates the federal common law substantial compliance
doctrine and requires the Plan to strictly follow the terms of
the plan documents and Kleinfeldt's original designation of
beneficiary.
 Recently, however, the Sixth Circuit rejected a similar ar-
gument that invoked Kennedy to challenge the continued via-
bility of the common law "slayer rule" (this rule bars a desig-
nated beneficiary, who murders the plan participant, from
benefiting from the crime). Standard Ins. Co. v. Guy, 115 F.4th
518 (6th Cir. 2024). Although the argument appeared persua-
sive "[a]t first blush," the Sixth Circuit observed, "Kennedy it-
self provided several reasons to believe that ERISA's pay-the-
designated-beneficiary rule admits of some, if few, excep-
tions," with the slayer rule being one. Id. at 523.
 Similarly, there is reason to think that the substantial com-
pliance doctrine survives Kennedy in circumstances like those
before us. For when a plan administrator does not exercise its
discretion to make a final beneficiary determination and in-
stead leaves it up to the court, "the need for the straightfor-
ward administration of plans and the avoidance of potential
double liability—while central to the Supreme Court's deci-
sion in Kennedy, are not implicated." Est. of Kensinger v. URL
Pharma, Inc., 674 F.3d 131, 136 (3d Cir. 2012) (holding that Ken-
nedy does not apply when one potential beneficiary of an
ERISA plan has sued another after the plan administrator has
 12 No. 25-1859

disbursed the funds); 3 see also Hall v. Metro. Life Ins. Co., 750
F.3d 995, 1000 (8th Cir. 2014) (observing courts may invoke
substantial compliance doctrine in interpleader actions and
when conducting de novo review) (citations omitted). But, be-
cause we think Langdon prevails either way, we will assume
without deciding the continued viability of the substantial
compliance doctrine here. Cf. id. at 999 (assuming substantial
compliance doctrine applies post-Kennedy when deciding the
case).
C. Substantial Compliance
 PCA's plan documents provided Kleinfeldt with specific
instructions on how to change the beneficiary to his retire-
ment account: "You should keep your beneficiary designation
and your beneficiary's address up to date. To do so, contact
the PCA Benefits Center … or you can update your beneficiar-
ies online." Instead of following this procedure, Kleinfeldt

 3 Accord Gelschus v. Hogen, 47 F.4th 679, 685 (8th Cir. 2022) ("[E]very
circuit to address the question [whether a personal representative may sue
a recipient of ERISA benefits after distribution] holds that ERISA does not
preempt such suits."); Andochick v. Byrd, 709 F.3d 296, 299–300 (4th Cir.
2013) ("[W]e conclude that permitting post-distribution suits [between
competing beneficiaries] accords with the ERISA objectives discussed in
Kennedy."); MetLife Life & Annuity Co. of Conn. v. Akpele, 886 F.3d 998, 1007
(11th Cir. 2018) ("This court likewise holds as mandated by the Supreme
Court in Kennedy that a party who is not a named beneficiary of an ERISA
plan may not sue the plan for any plan benefits. A party, however, may
sue a plan beneficiary for those benefits, but only after the plan beneficiary
has received the benefits.").
 No. 25-1859 13

submitted his change request via a fax sent on October 4,
2022. 4
 To determine whether Kleinfeldt's actions met the sub-
stantial compliance doctrine, we consider whether "the in-
sured (1) evidenced his intent to make the change and (2) at-
tempted to effectuate the change by undertaking positive ac-
tion which is for all practical purposes similar to the action
required by the change of beneficiary provisions of the pol-
icy." Davis, 294 F.3d at 941 (citation modified) (adopting the
federal common law substantial compliance test as articu-
lated in Phoenix Mut. Life Ins. Co. v. Adams, 30 F.3d 554, 564
(4th Cir. 1994)); see also Johnson, 297 F.3d at 567 (noting Sev-
enth Circuit's adoption of the Phoenix Mutual test).
 1. Intent
 The first element is undeniably met here: Kleinfeldt's fax
unequivocally evidences his intent to make a change of bene-
ficiary. The fax instructs the Plan to "remove my former
spouse, Dená Suzanne Kleinfeldt, from the health, vision[,]
and dental insurance and as a beneficiary of my 401(k), pen-
sion[,] and life insurance accounts."
 Unconvinced, Langdon points to the subsequent sentence
in the fax which reads: "Please feel free to fax any necessary
paperwork to the above fax that I may need to complete." Id.
This, she argues, demonstrates that Kleinfeldt knew the fax
alone was insufficient to remove Langdon as a beneficiary.

 4 Langdon disputes that Kleinfeldt "sent" the fax, saying it was actu-
ally sent by Jordan Renn, an HR manager at PCA In her proposed facts,
however, Langdon admits that Kleinfeldt directed Renn to send the fax,
so we think this distinction immaterial.
 14 No. 25-1859

But substantial compliance does not require the participant to
believe they have completed every step in the process. See Da-
vis, 294 F.3d at 931 (citation modified) (substantial compliance
does not require a plan participant to do "all that he could
have done."). Even under Langdon's view of the record,
Kleinfeldt's fax is a clear expression that he wanted Langdon
removed from all of his benefit plans, including his retirement
plan.
 2. Positive Action
 Whether Kleinfeldt undertook "positive action which is
for all practical purposes similar to the action required by" the
plan documents, Davis, 294 F.3d at 941 (citation modified), is
a closer question and requires a deeper dive into our prior ap-
plication of the doctrine.
 In Johnson, for example, the decedent completed the bene-
ficiary-change form the plan documents required but made
minor clerical errors, such as listing the wrong address and
marital status, before returning the form to his employer. 297
F.3d at 560–61. In holding that the substantial compliance doc-
trine was met, we emphasized that the decedent had utilized
the correct procedure and that the administrator had every-
thing it needed to know what the decedent wanted to accom-
plish. Id. at 568 (finding substantial compliance where the de-
cedent "filled out [the required] form," "designated [persons]
as the new beneficiaries," and received a "confirmation letter
indicating that he mailed the form as required.").
 Similarly, in Davis, the decedent completed the required
change-of-beneficiary form, designated a new beneficiary,
and returned the form to the plan administrator, who ac-
cepted and processed the form as though it was complete. The
 No. 25-1859 15

decedent's only failing was not signing and dating the form.
294 F.3d at 942. "On these facts," we observed, "her failure to
sign and date the form can only be construed as carelessness"
and found that the decedent had substantially complied with
the plan's change-of-beneficiary requirements. Id.
 Likewise, in Aetna Life Ins. Co. v. Wise, 184 F.3d 660, 662
(7th Cir. 1999), the decedent had a life insurance policy spon-
sored by his employer. After divorcing his first wife, he suc-
cessfully completed a change-of-beneficiary form and desig-
nated his parents as beneficiaries. Id. He got remarried, how-
ever, and replaced his parents with his second wife. Id. After
another divorce, he informed his employer and received an
enrollment form and verification of divorce. Id. The cover let-
ter instructed him that, to remove his second ex-wife as a ben-
eficiary, he needed to complete the portions on the form
marked with an "X." Id. The problem was that the employer
had failed to mark the beneficiary designation portion of the
form with an "X," and the decedent completed all of the
marked sections, returned the form, but left the beneficiary
designation section blank. Id. at 663. Later that year, he exe-
cuted a will evidencing his intent to leave all of his assets to
his parents and committed suicide the following day. Id. at
662–63. Given such facts, we had little trouble finding that the
decedent had done "everything he could have reasonably
done to carry out his intention to change the beneficiary" of
his life insurance policy. Id. at 664. 5

 5 Although our decision in this case was based on our analysis of Illi-
nois common law, we have observed elsewhere that the Illinois doctrine
of substantial compliance and the federal common law test "are essentially
the same." Johnson, 297 F.3d at 567.
 16 No. 25-1859

 By contrast, consider Rendleman v. Metropolitan Life Insur-
ance Co., 937 F.2d 1292 (7th Cir. 1991). That case involved a
dispute over the proceeds of a life insurance policy. The in-
sured underwent a divorce and, soon afterwards, dropped his
ex-wife from his group health insurance program provided
by his employer. He then told a co-worker that he intended to
remove his ex-wife as a beneficiary to his life insurance policy
as well, but there was no evidence that he ever obtained the
change-of-beneficiary form that his policy required or com-
pleted such a form. Id. at 1294. Applying Illinois common law
principles of substantial compliance, we held that the dece-
dent had not met the test because "he was aware of the neces-
sary procedure for effectuating a change in his life insurance
coverage and simply failed to do so." Id. at 1297.
 Another illustrative example (albeit outside our circuit) is
Prudential Insurance Co. of America v. Schmid, 337 F. Supp. 2d
325, 327 (D. Mass. 2004). There, the decedent attempted to
name his second wife as the beneficiary of his employer-spon-
sored life insurance policy. During a phone call with the in-
surer, the decedent informed an agent that he wished to des-
ignate his wife as the beneficiary for his life insurance policy.
Id. The insurer's agent incorrectly told him that his wife was
already the designated beneficiary, so the decedent did not
complete the necessary change-of-beneficiary form. Id. Rely-
ing on Phoenix Mutual, the court concluded that, as a matter
of federal common law, the decedent had not substantially
complied with the policy's requirements because the "tele-
phone conversation [did] not suffice as a positive act to ac-
complish [decedent's] intent" and he had not even attempted
to fill out a change-of-beneficiary form. Id. at 332.
 No. 25-1859 17

 Here, appellants argue that Kleinfeldt's sending of the fax
to PCA "is for all practical purposes similar to" the proce-
dures set forth in the plan documents. We disagree. In those
cases where we found substantial compliance, the plan par-
ticipants took pains to follow the procedures the plan re-
quired, including obtaining the appropriate forms and even
completing them to the extent they were able. But, here, Klein-
feldt did not even attempt to utilize the proper procedures.
Nowhere in the plan documents is the participant allowed to
request a beneficiary change via fax. Put another way, the
manner Kleinfeldt chose to remove Langdon as a beneficiary
evidences much more than "careless error," Davis, 294 F.3d at
941; it is a method that deviates materially from the Plan's
terms and falls short of being "for all practical purposes simi-
lar to" the procedures required by the plan documents, John-
son, 297 F.3d at 566 (citation modified).
 Indeed, in his message, Kleinfeldt requested that the Plan
"fax [him] any necessary paperwork … that [he] may need to
complete" to effectuate the beneficiary change. This suggests
that, although Kleinfeldt certainly wanted to remove Lang-
don as a beneficiary, he himself understood that further steps
may have been required to do so. Rather than following up
with PCA, however, Kleinfeldt did nothing more.
 On these facts, we hold that Kleinfeldt did not substan-
tially comply with the plan's beneficiary-change require-
ments. As such, at his death, Langdon remained the primary
beneficiary, and Scholz's estate the contingent beneficiary. 6

 6 Because we hold that Langdon was the primary beneficiary, we need
not address the parties' remaining arguments.
 18 No. 25-1859

 * * *
 For the foregoing reasons, the judgment is REVERSED
and REMANDED for entry of judgment for Langdon.