"Every publicly held corporation should confirm that none of its plans or arrangements that are subject to Section 409A ... require that payment be delayed until the Section 162(m) limit no longer applies. Arrangements that are subject to 409A can include employment agreements and severance agreements, as well as SERPs, RSUs, and other arrangements that are traditionally considered to be deferred compensation. Any plan or agreement that includes a mandatory Section 162(m) deferral should be amended by December 31, 2020[.]"