"[T]he Ninth Circuit appears to have confused two distinct requirements imposed by ERISA's duty of prudent investing: the duty to be prudent in the selection of plan investment options, and the duty thereafter prudently to monitor the selected investment options, to ensure that those options remain prudent choices.... Contrary to congressional intent, this interpretation of ERISA's six-year statute of limitations insulates fiduciaries from liability for imprudent behavior -- namely, omitting to provide prudent monitoring -- with regard to ongoing plan investment options, as long as that imprudent behavior occurs more than six years after the initial investment selection." [Tibble v. Edison International, No. 13-550 (9th Cir. Aug. 1, 2013; cert. pet. granted Oct. 2, 2014)]