"[T]he Court's analysis makes it less likely that fiduciaries will be able to have duty-to-monitor claims dismissed on statute of limitations grounds before substantial discovery takes place.... [T]he precise scope of the duty to monitor is now fertile ground for additional litigation.... [The opinion] declares that 'a fiduciary normally has a continuing duty of some kind to monitor investments and remove imprudent ones' within a reasonable time.... [This language] supports the notion that, in most cases, ERISA fiduciaries should completely remove investment funds they deem to be imprudent from the plan's lineup." [Tibble v. Edison Int'l, No. 13-550 (U.S. May 18, 2015)]