"The U.S. Court of Appeals for the Second Circuit has ruled that New York's anti-subrogation statute ... applies both to 'offsets' for prospective benefit payments and to reimbursements for prior benefit disbursements. In so holding, the Second Circuit ruled that a Plan's choice-of-law provisions may not be dispositive of which jurisdiction's anti-subrogation statute will apply to govern disbursement and/or recovery of that Plan's assets." [Arnone v. Aetna Life Ins. Co., No. 15-2322 (2d Cir. June 22, 2017)]  MORE >>