FASB’s Invitation to Comment – Agenda Consultation
SIFMA provided comments to the Financial Accounting Standards Board (FASB) on its Invitation to Comment - Agenda Consultation (the “ITC”).
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.
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