On August 5th, a Federal District Court held that JP Morgan Chase ("JPMC") did not breach the duty of loyalty it owed its clients. Plaintiffs alleged that JPMC violated ERISA and state fiduciary duty law by investing certain securities lending clients' cash collateral in the medium-term notes of Sigma Finance, a structured investment vehicle that collapsed. Assuming, without deciding, that JPMC may have breached its duties to prudently manage plan assets, the court held that JPMC's extension of repo financing to a non-fiduciary client (Sigma) in a non-fiduciary capacity did not constitute a conflict of interest. Board of Trustees of the AFTRA Retirement Fund v. JP Morgan Chase Bank, N.A.