The Court of Appeals for the First Circuit has ruled that Citigroup’s Capital Accumulation Plan did not violate Colorado or Louisiana wage and labor laws. Under the plan, certain employees could elect to receive a portion of their earned commissions in the form of Citigroup stock at a 25 percent discounted price and on a tax-deferred basis. The tax-deferred feature existed because the stock was subject to a two-year vesting period. Certain employees resigned before the vesting period had been completed and Citigroup forfeited the restricted shares. In a series of cases filed in many states, the former employees claimed that the forfeiture of the stock violated wage laws because the forfeiture resulted in the loss of wages that were used to purchase the restricted stock. The First Circuit found that the plan did not violate the laws of Colorado or Louisiana in that unvested forms of compensation were not protected and were not owed to employees at the time of termination of their benefits. (Renaudin v. Citigroup Global Markets Inc. [In re Citigroup Inc. Capital Accumulation Plan Litigation], 1st Cir. 2011)