"[T]he Seventh Circuit ... reasoning differs slightly from the lower court in at least one significant respect that is supportive of the idea that ERISA claims can be arbitrated. But in other respects, the Seventh Circuit's decision points to some possible limits on what plan sponsors may require be arbitrated. The upshot is continued uncertainty that plan sponsors will have to navigate to the extent they wish to require arbitration of ERISA claims." [Smith v. Bd. of Directors of Triad Mfg., Inc., No. 20-2708 (7th Cir. Sept. 10, 2021)]  MORE >>