"Although some lower courts have held that deference must be provided to hard-wired plan documents, the Supreme Court ... emphasized that ERISA recognizes that the duty of prudence can conflict with the terms of a plan document ... [The] Court held that ERISA precludes a fiduciary's slavish adherence to the terms of plan documents without considering ERISA's separate obligations.... [F]iduciaries of all plans should evaluate the prudence of even mandatory plan provisions in light of Dudenhoeffer." [Fifth Third Bancorp v. Dudenhoeffer, No. 12-751 (U.S. June 25, 2014)]