4th Circuit Affirms That Merrill Lynch Bonus Plan Falls Outside ERISA

( April 23, 2026, 10:51 AM EDT) -- RICHMOND, Va. — As urged by the appellees and a handful of amici curiae, the Fourth Circuit U.S. Court of Appeals agreed that an incentive compensation program “qualifies as a ‘bonus plan exempt from’” the Employee Retirement Income Security Act, affirming summary judgment against a former financial adviser who filed the putative class action; one panel member wrote a concurring opinion to emphasize “that any other conclusion would generate an avalanche of deleterious consequences.”...