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Text of DOL Advisory Opinion 2025-03A: Applicability of ERISA to Morgan Stanley Deferred Incentive Compensation Program
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL] 
[Official Guidance] Sept. 10, 2025 "[In] the Department's view, the mere fact that the terms of the program contemplate limited situations where an award could be paid after termination of employment does not implicate a deferral of income of the kind contemplated by ERISA section 3(2)(A). Thus, the Department has no reason to believe that the deferred incentive compensation program is an employee benefit pension plan under ERISA section 3(2)(A) as a result of such surrounding circumstances." MORE >> |
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