My employer has a nonqualified deferred comp plan for executives that utilizes the 1983 Group Annuity Mortality Table (83 GAM). My question is the following: Does ERISA or some other regulation require that the Plan be amended to use the 1994 Group Annuity Reserving Table (94 GAR)? Or is it up to the employer if it wants to change from using the 83 GAM to the 94 GAR?

Employer can use any mortality table it wants for a nonqualified plan.

It depends. While there is no legal requirement to change it for plan purposes, there may be an accounting requirement to change the mortality table for measuring long term liabilities. That would be up to the accountants, I suppose.