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FIRST AMENDMENT TO THE ORIGEN
FINANCIAL, LLC
ENDORSEMENT SPLIT-DOLLAR PLAN
This First
Amendment to the Origen Financial, LLC Endorsement Split-Dollar
Plan (this “Amendment”) is made by Origen Financial,
LLC, a Delaware limited liability company (the
“Company”) on December 15, 2008. Capitalized terms
used but not defined herein shall have the meanings set forth in
the Origen Financial, LLC Endorsement Split-Dollar Plan, as amended
(the “Plan”).
A. The
Company maintains the Plan for the benefit of a select group of
management or highly compensated employees to provide life
insurance benefits in the event of the employee’s
death.
B. The
Internal Revenue Service issued final regulations regarding the
application of Internal Revenue Code (“Code”) section
409A to nonqualified deferred compensation plans, including
split-dollar life insurance arrangements, with an effective date of
January 1, 2008.
C. Because
the Plan is subject to Code section 409A, the Company desires to
amend the Plan to meet the requirements of Code section 409A and
the accompanying final regulations.
D. Under
Section 16 of the Plan, the Company may amend the Plan if the
amend
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