"[T]he Seventh Circuit affirmed a [district court] ... decision holding that Illinois's anti-discretionary clause regulation ..., [which prohibits] discretionary clauses in insured employee benefits plans offered or issued in Illinois, was outside the scope of the preemption power of [ERISA].... [T]he Seventh Circuit ... applied its two-part test for determining whether a law 'regulates insurance.' The court stated that [the Illinois regulation] was [1] 'specifically directed toward entities engaged in insurance' and [2] 'substantially affect[ed] the risk pooling arrangement between the insurer and the insured.' " [Fontaine v. Metropolitan Life Ins. Co., No. 14-1984 (7th Cir. Sept. 4, 2015)]  MORE >>