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Are Your Executive Compensation Arrangements Safe from the New Disability Regs?
McDermott Will & Emery
[Guidance Overview] Feb. 13, 2018
"[W]hether the Final Rule applies to an executive compensation arrangement is dependent on [1] whether the particular executive compensation is subject to ERISA and thereby ERISA's claims procedure requirements, [2] whether there is a disability payment trigger under the executive compensation arrangement and [3] how the disability determination is made under the executive compensation arrangement."
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