Advance Notice of Proposed Rulemaking on Reconsideration of Personal Financial Data Rights Rule
SIFMA provided comments to the Consumer Financial Protection Bureau (CFPB) on the Advance Notice of Proposed Rulemaking on Reconsideration of…
Summary
Court:
U.S. Court of Appeals
(Second Circuit)
Amicus Issue:
Whether employees can retrospectively recast deferred compensation programs as “ERISA plans” and thereby be entitled, under ERISA’s vesting and anti-forfeiture rules, to payment of deferred compensation even if the employees leave before the awards have vested or otherwise fail to meet the agreed-upon terms of the awards.
Counsel of Record:
Orrick Herrington & Sutcliffe LLP
Michael Delikat
Robert M. Loeb
Alyssa Barnard-Yanni
Other Amici:
None.
More Submissions
Type:
Modernizing Communications and Record Retention Rules for Broker-Dealers,Investment Advisers, and Security-Based Swap Dealers (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) requesting that the SEC take necessary…
Type:
Proposed Rule Change to Amend the Exchange’s Rules to Enable the Trading of Securities on the Exchange in Tokenized Form
SIFMA provided comments to the U.S. Securities and Exchange Commission (SEC) in response to the proposal by The Nasdaq Stock…