Fiduciary Duty Breach- Low Causation Proof Needed

In Breach of Fiduciary Duty cases - no "proximate cause" is needed, only a lower burden of "substantial factor" applies. ("Because [a]n action for breach of fiduciary duty is a prophylactic rule intended to remove all incentive to breach — not simply to compensate for damages in the event of breach, there need not be but-for causation between the breach and the asserted damages, ..." (alteration in original) (citations and quotation marks omitted)). Accordingly, the Citco. Anwar v. Fairfield Greenwich Ltd., 728 F. Supp. 2d 372 - Dist. Court, SD New York 2010

BOFD- in other cases have noted: theie Second Circuit has "lowered the standard from proximate causation to `substantial factor causing the loss.'" And with respect to the breach of fiduciary duty c lesser "substantial factor" test applies under New York law.