Excerpt: Addressing allegations that a mutual fund investment adviser breached its fiduciary duty under the Investment Company Act of 1940 by charging excessive fees, a unanimous US Supreme Court has ruled an adviser faces liability only if the fee 'is so disproportionately large that it bears no reasonable relationship to the services rendered and could not have been the product of arm's length bargaining' (Jones v. Harris Assoc.). Though the case did not involve ERISA issues, the ruling could color analysis of claims that excessive 401(k) fees violate ERISA fiduciary standards.