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Articles by Caroline Dorsey
Almost 20 Years Of Section 409A: Is Your Documentation Still In Sync?
SS Seyfarth Shaw LLP More With approximately 1,000 lawyers across 17 offices, Seyfarth Shaw LLP provides advisory, litigation, and transactional legal services to clients worldwide. Our high-caliber legal representation and advanced delivery capabilities allow us to take on our clients’ unique challenges and opportunities-no matter the scale or complexity.
Almost 20 Years of Section 409A: Is Your Documentation Still in Sync?
It has been nearly 20 years since Internal Revenue Code Section 409A transformed the rules governing nonqualified deferred compensation (NQDC). Many employers updated written plan documents by the 2008 deadline—and haven’t touched them since. As the 20‑year mark approaches, now is the perfect moment for a quick compliance check. Over time, plan administration often drifts from what the written document actually says.
Global Anti-Corruption Insights: Winter 2026
Arnold & Porter are most popular: with readers working within the Retail & Leisure industries Although President Trump temporarily paused enforcement of the U.S. Foreign Corrupt Practices Act (FCPA) in the first half of 2025, U.S. Department of Justice (DOJ) officials recently have declared that enforcement of the FCPA — and other criminal laws that apply to international business conduct — remains alive and well.
Global Anti-Corruption Insights: Winter 2026
Although President Trump temporarily paused enforcement of the U.S. Foreign Corrupt Practices Act (FCPA) in the first half of 2025, U.S. Department of Justice (DOJ) officials recently have declared that enforcement of the FCPA — and other criminal laws that apply to international business conduct — remains alive and well. In the second half of 2025, two companies negotiated agreements with DOJ to resolve FCPA investigations, and a third came under indictment.
There May Still Be Work for Retirement Plans After the Check is in the Mail | JD Supra
A recent complaint (Dylan Handy v. Paychex, Inc.) highlights the potential for plan administrators, and their delegates, to continue monitoring distributions after being made. In this particular situation, the participant requested a distribution from his 401(k) account administered by Paychex in April 2023 to rollover to another financial institution. Consistent with the plan’s process, he received his account in two checks totaling over $100,000, which he forwarded to a financial institution.
From Stable to Shaky: What Bed Bath & Beyond’s Settlement Means for Retirement Plan Sponsors | JD Supra
In February, Bed Bath & Beyond, Inc.’s 401(k) Savings Plan Committee (the “Plan Committee”) agreed to pay $1,950,000 to participants in the Bed Bath & Beyond, Inc. 401(k) Savings Plan (the “Plan”) whose accounts were invested in the Plan’s stable value fund.
A Plan Win in an ESG Case … For the Most Part | JD Supra
A New York Appellate court affirmed a dismissal of a fiduciary breach claim against the New York City Employees’ Retirement System, Teachers’ Retirement System of the City of New York, and Board of Education Retirement System of the City of New York (Wayne Wong et al. v. New York City Employees’ Retirement System et al.) related to decisions by fiduciaries that divested fossil-fuel based investments.
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