Whether the Second Circuit erred in holding that it must disregard all objective extrinsic evidence of the reasonableness of an ERISA plan administrator's interpretation of plan terms if the court views the plan terms as unambiguous

QUESTIONS PRESENTED This Court has repeatedly held that when an ERISA plan expressly confers upon the plan administrator discretion to interpret its terms, that interpretation should stand unless arbitrary and capricious. See Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989); Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (2008); Conkright v. Frommert, 559 U.S. 506 (2010). In declining to defer to the reasonableness of the Colgate plan administrator’s interpretation of key plan provisions, the Second Circuit departed from this line of cases and deepened two separate circuit splits. The questions presented are: 1. Whether the Second Circuit erred in holding, contrary to decisions of the Seventh Circuit, that it must disregard all objective extrinsic evidence of the reasonableness of an ERISA plan administrator’s interpretation of plan terms if the court views the plan terms as unambiguous within the four corners of the plan. 2. Whether the Second Circuit erred in holding, contrary to decisions of the Ninth and Tenth Circuits, that an ERISA plan administrator’s reasonable interpretation of plan terms receives no deference if the plan terms at issue involve actuarial assumptions used to determine a plan participant’s benefits.