"The Court's Church Plan decision may intersect with its recent decision in Spokeo Inc. v. Robbins ... [which] said that a plaintiff must allege a 'concrete injury' to bring suit ... To be sure, some [of the church plan] plaintiffs also allege a clearly concrete injury -- for example, an actual loss of benefits due to the plan's vesting schedule that fails to meet ERISA minimums. But under Spokeo, it is unclear if alleged funding, fiduciary and reporting and disclosure 'injuries,' in the absence of a specific, personal harm, or non-speculative risk of harm, would pass muster as sufficiently concrete[.]"

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