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California’s Board and Ethnic Diversity Statutes Declared Unconstitutional

In a ruling on April 1, 2022, a Superior Court in the County of Los Angeles invalidated Assembly Bill 979 (“AB 979”), a California bill requiring increased diversity on public company boards, which was signed into law by...more

Time to Consider Option Repricings?

Given recent declines in equity value in a variety of segments of the economy (technology in particular), a number of clients have asked us what levers are available for retaining talent. While they are rare and while we...more

Short-Term Deferral Day is Right Around the Corner

Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.” Specifically, Section 409A...more

2021 End of Year Plan Sponsor “To Do” List (Part 4) Executive Compensation

As is tradition, we are happy to present our End of Year Plan Sponsor “To Do” Lists. We are publishing our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered year-end health and welfare plan issues, Part...more

2021 End of Year Plan Sponsor “To Do” List (Part 3) Qualified Retirement Plans

As 2021 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. Part 1 covered health and welfare plan...more

2021 End of Year Plan Sponsor “To Do” List (Part 2) Annual Cost of Living Adjustments

As is tradition, we are happy to present our End of Year Plan Sponsor “To Do” Lists. We are publishing our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered year-end health and welfare plan issues. This...more

2021 End of Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

In Case You Missed It – Summer 2021

Summer has come and gone, but there was no summer vacation for employee benefits legislation and guidance. In case you have been too busy to check out our blogs lately, here are some key items to help you stay organized and...more

SEC Approves Nasdaq’s Board Diversity Rules

On August 6, 2021, the Securities and Exchange Commission (“SEC”) adopted the Nasdaq Stock Market LLC’s (“Nasdaq”) proposed board diversity rule. The rule is intended to encourage greater board diversity by requiring board...more

Updated Nonqualified Deferred Compensation Plan Audit Guide

In June the Internal Revenue Service released an updated Nonqualified Deferred Compensation Audit Technique Guide. This updated Guide replaces the initial Guide published in 2015. While it is too early to say whether the...more

2020 End of Year Plan Sponsor “To Do” List (Part 4) - Qualified Retirement Plans

As 2020 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. Part 1 covered health and welfare plan...more

2020 End of Year Plan Sponsor “To Do” List (Part 3) - Executive Compensation

As 2020 comes to an end, we are happy to present our traditional End of Year Plan Sponsor “To Do” Lists. We are publishing our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered year-end health and...more

ISS Releases Additional Executive Compensation COVID-19 Related Guidance

As we previously reported in prior S&W Benefits Updates (links below), the executive compensation related challenges presented to management and corporate boards from COVID-19 are significant. Among other considerations,...more

2020 End of Year Plan Sponsor “To Do” List (Part 2) Annual Cost of Living Adjustments

As 2020 comes to an end, we are happy to present our traditional End of Year Plan Sponsor “To Do” Lists. We are publishing our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered year-end health and...more

California is First State to Mandate Public Company Board Diversity

With the issues of social justice, systemic racism, bias and inequality drawing heighted attention since George Floyd’s killing, the passage of AB-979 makes California the first state to require public companies with their...more

ISS Publishes COVID-19 Case Study Focused on Executive Compensation Adjustments

As we previously reported in prior SW Benefits Updates, the challenges presented to management and corporate boards from COVID-19 are significant. Among other considerations, companies might adjust 2020 performance goals,...more

COVID-19 Related Cancellations of NQDC Elections

As a general matter, deferral elections under non-qualified deferred compensation plans (“NQDCs”) cannot be cancelled unless a NQDC plan participant incurs an “unforeseeable emergency” or “disability” as each such term is...more

Glass Lewis, COVID-19 and Public Company Executive Compensation

As noted in a prior S&W Benefits Update, the spread of COVID-19 is impacting executive compensation programs in a meaningful way. Among other approaches, our update suggested that management and their corporate boards might...more

IRS Continues to Extend Key Filing Deadlines in Response to COVID-19

On April 9. 2020, the Internal Revenue Service (the “IRS”) issued Notice 2020-23, which extends a number of key filing deadlines in the wake of the COVID-19 pandemic. The guidance provides welcome relief to individuals and...more

ISS Follows Glass Lewis and Issues COVID-19 Public Company Executive Compensation Guidance

As noted in my S&W Benefits Update from Tuesday, Glass Lewis (“GL”) recently provided guidance on its approach to balancing management and board executive compensation decisions in response to the COVID-19 pandemic. Yesterday...more

Tax-Favorable COVID-19 Pandemic Relief for Employees and Employers Covered by Section 139 Programs

With life upended for many employees during the COVID-19 pandemic, we want to highlight one way for employers to offer potential tax-favorable financial relief: implementing a disaster relief program under Section 139 of the...more

COVID-19 and Public Company Executive Compensation Programs

The spread of COVID-19 is having an unimaginable impact on all facets of life, including our economy. While executive compensation programs might not be the most pressing issue facing corporate boards right now, volatility in...more

Updated Glass Lewis Proxy Voting Guidelines

I previously blogged about certain compensation related updates to ISS’ proxy voting guidelines for 2020. With proxy season in full swing, I wanted to highlight some important compensation related changes to the Glass Lewis...more

2019 End of Year Plan Sponsor “To Do” List (Part 4) - Executive Compensation

As 2019 comes to an end, we are happy to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered year-end health and...more

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