"On appeal, the Second Circuit determined that the plan's provisions 'establish a subjective standard by which [the insurer] can make claims eligibility decisions', and, therefore, the plan delegates discretionary authority to the insurer over benefit claims and denials. It ruled that the word 'reasonable' indicates a discretionary standard because there is a broad range of permissible choices within which the insurer may resolve claims." [Tyll v. Stanley Black & Decker Life Ins. Program, No. 20-1060 (2d Cir. May 4, 2021, unpub.)]