"The foreseeability of loss, a core principle of Palsgraf, is relevant and probative in fiduciary litigation. The plan sponsor's decision to offer an annuity product that actuarially cannot provide a commensurate return -- and predictably results in a participant financial loss absent exceptional longevity -- is a breach of both the duty of prudence and loyalty. The financial harm to the participant was not a remote or unexpected event, but rather an inherent, foreseeable outcome of the annuity's structure."  MORE >>