A new fiduciary case alleges that TIAA and Morningstar colluded to alter asset allocation tools to promote certain TIAA annuities. The case is directed at TIAA and Morningstar, rather than at plan sponsors—and could create liability for TIAA and Morningstar for both ERISA and non-ERISA plans. The complaint rehashes some old criticism of TIAA—but also contains some significant new accusations. If this case succeeds, it could have some far-reaching implications.