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Sarbanes-Oxley and Nonqualified Deferred Compensation Plan


Guest AEA

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How do the provisions of the Sarbanes-Oxley Act of 2002 affect nonqualified plans? Primarily, I'm concerned about the new reporting requirements under section 16. I have a client who sponsor a nonqualified deferred compensation plan (holds deferrals in excess of 401(k) plan and matching contributions) that allows participants to "suggest" investments in employer stock.

I cannot find clear language helping me determine which reporting rules apply to this plan. Can anyone help?

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