At common law, trust fiduciary law generally “resolves into two great principles, the duties of loyalty and prudence … Sub-rules of fiduciary administration abound … All of these rules are subsumed under the duties of loyalty and prudence, they are means of vindicating the beneficial interest.” Of these two great principles, the duty of loyalty has been described as the “essence” of the fiduciary relationship. Loyalty dictates that the trustees act for the sole benefit of the beneficiary: “The duty of loyalty requires the trustee ‘to administer the trust solely in the interest of the beneficiary.’ This obligation implements the beneficiaries’ entitlement to the trust assets. The trustee owns the assets, but only to facilitate the beneficiaries’ enjoyment.”
 John H. Langbein, “The Contractarian Basis of the Law of Trusts,” 105 Yale L.J. 625, 655-6 (1995)[hereinafter Langbein, “Contractarian”].