"The Ninth Circuit ... explained that the interest does not accrue until the benefit becomes payable and a benefit only becomes payable after the submission of a claim in line with the terms of the life insurance policy.... [T]he court rejected Workman's argument that Dearborn breached its fiduciary duties under ERISA by retaining a profit on interest from the insured's policy benefit. The guaranteed benefit policy amount is the asset [of] the ERISA plan. Thus, an insurer's fiduciary duties extend only to the disposition of the guaranteed benefit." [Workman v. Dearborn National Life Insurance Company, No. 20-55182 (9th Cir. Dec. 29, 2021)]