Fourth Circuit: Jeffrey Quatrone v. Gannett Company, Inc.

  Plan's retention of substantial amounts of spun-off business' stock in a single stock fund states a claim against the Administrator's common law duty of prudence.

While allowing the participants to select funds can satisfy the statutory duty of diversification, it does not address common-law prudence.

Liability is possible where a frozen defined contribution plan does not timely divest the single-stock fund.

Dissent: 

Participants could allocate their investments.  The fact that prudence and diversification are codified separately means that they shouldn't be merged in common-law analysis.

[Again, folks, just my scribbling.  This is never legal advice.]



Jeffrey Quatrone v. Gannett Company, Inc.