"[T]wo recent decisions ... addressed allegations that retirement plan fiduciaries had breached their duties under [ERISA] by offering allegedly imprudent investments in employer securities and by misrepresenting or concealing material information about the company. Applying different standards to reach opposite outcomes, the Second Circuit affirmed the dismissal of such claims, while the Sixth Circuit reversed dismissal and remanded, thereby widening a circuit split over pleading standards for [these] claims."  MORE >>