"[T]he heart of the dispute was whether the Plaintiffs possessed a remedy under ERISA Section 502(1)(1)(B). To answer this question, the Second Circuit merely stated, 'in the absence of controlling authority otherwise, we are inclined to follow the Supreme Court's express preference that violations of ERISA should be remedied.' This open-ended conclusion has the potential to only enhance the ambiguity on this issue and foster a split among the circuits on a participant's remedies under ERISA Section 502(a)(1)(B)." [Laurent v. PricewaterhouseCoopers LLP, No. 18-487 (2d Cir. Dec. 23, 2019)]