"[T]he Sixth Circuit held that an ESOP fiduciary's investment decisions satisfy the ERISA duty of prudence so long as the fiduciary uses a prudent process when the decisions are made. Further, a public company stock's current market price is deemed to be a reliable indicator of the stock's value, absent a showing of special circumstances by the plaintiffs as to why that price is not reliable. This is true even if in hindsight stock losses occur. This case represents good news for fiduciaries of plans that require investment in employer stock -- even though the days of a presumption of prudence are gone." [Pfeil v. State Street, No. 14-1491 (6th Cir. Nov. 10, 2015)]  MORE >>