The Securities Industry Association (SIA)* provides comments to the Internal Revenue Service (IRS) on proposed regulations issued relating to Section 409(a) of the Internal Revenue Code, REG-158080-04.  SIA voices its concerns over certain discrete portions of the proposed regulations relating to payments on account of conflicts of interest, application to participation in non-US deferred compensation plans, and settlement of compensatory stock options.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.