"The FAB represents a meaningful recalibration of EBSA's enforcement posture.... [T]he emphasis on loyalty over prudence as an enforcement priority ... underscores the importance of maintaining robust fiduciary governance processes and thoroughly documenting decision-making.... [T]he explicit mention of ESG objectives as an example of goals 'unrelated to participants' best interests' signals continued scrutiny of ESG-related investment strategies and activities (including proxy voting) for ERISA plans.... [T]he commitment not to regulate by enforcement should provide an opportunity for fiduciaries to defend good faith processes.... [T]he new investigation timelines and quarterly review requirements reflect a welcome commitment to efficiency."  MORE >>