"[T]he Supreme Court's decision -- that a fiduciary's duties cover not only the selection of investments, but also their regular review -- is likely to have added to fiduciaries' uneasiness. Not because of the requirement to monitor: if I'd asked a random fiduciary last week whether they thought they had an obligation to keep an eye on their investments, I don't think many would have said 'no', or even 'only until the Statute of Limitations kicks in'. Rather, it's that here is one more aspect of the fiduciary's role which is now in a state of flux: it will take some time to lock down exactly what the required review process is expected to involve."