Advance Notice of Proposed Rulemaking on GENIUS Act Implementation (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Department of the Treasury (DOT) in response to the Department 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:
Citigroup v. Otto Candies
Court: U.S. Supreme Court (pet. for writ of cert.) Amicus Issue: Whether Section 1964(c) of the Private Securities Litigation Reform…
Type:
Improving the Waiver Process and Rules Governing Certain Disqualifications Under the Federal Securities Laws
SIFMA provided comments to the U.S. Securities and Exchange Commission (SEC) requesting that it take necessary steps to improve the…