The scope of changes impacting investment advisers and broker-dealers wrought by the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd- Frank") is significant and growing as various government agencies act to implement the law.

As you know, we have been awaiting final regulations under Internal Revenue Code Section 409A. 409A governs "non-qualified deferred compensation." The IRS had previously set a Dec. 31, 2006, deadline to amend documents to comply with 409A.