Blog Post

Oct 19, 2011

The Second Circuit Adopts the “Moench Presumption”, Rejects Stock Drop Claims Against Citigroup.

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Joining at least the Third, Fifth, Sixth, and Ninth Circuits, in finding a presumption of prudence attaches when defined contribution plans offer employer stock as an investment option, a divided panel of the Second Circuit today affirmed the dismissal of ERISA “stock drop” claims against Citigroup in In re: Citigroup ERISA Litigation, 09-3804 (Oct. 19, 2011).  

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