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District Court Concludes That Defendants Had No Discretion to Eliminate or Liquidate Citigroup Stock Fund (PDF)
Proskauer Rose LLP 
[Guidance Overview] Oct. 8, 2009
Pages 1-2 of 5 pages. Excerpt: The Citigroup decision is noteworthy because the court focused on the plan terms to determine the appropriate scope of any fiduciary duties regarding investments in employer stock. The decision suggests that, if the terms are sufficiently explicit, they could eliminate the prospects of a viable fiduciary breach claim for failure to discontinue stock fund investments.
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