Devoted to Corporate Attorneys, Corporate Lawyers, and Corporate Counsel

The following is not meant to be legal advice.

All severance arrangements, equity-based compensation arrangements, and nonqualified deferred compensation plans that extend beyond December 31, 2007, should be reviewed for compliance with the final regulations. These arrangements and plans should be revised where necessary to bring into compliance with the final regulations.  This means that even if they were previously revised to comply with the proposed regulations, they need to be looked at again because the proposed regulations differ from the final regulations.  This may be a lesson to some not to take proposed regulations too seriously, and wait for the final regulations to offset unnecessary work.  The arrangements revised to comply with proposed regulations may not extend beyond December 31, 2007.  The deadline for revising the arrangements to comply with the final regulations is December 31, 2007.