Jenny L. Holmes

Jenny Holmes is an associate in Nixon Peabody’s Labor & Employment group and a member of the Employee Benefits and Executive Compensation team. She counsels clients on the design, drafting, implementation and ongoing operation of retirement plans, health and welfare plans and cafeteria plans.

Jenny is also an active member of the firm’s Privacy & Data Protection team, developing and implementing system-wide privacy and security plans for numerous companies of various sizes, including the creation of response plans.

What do you focus on?

I focus my practice on three primary areas:

Retirement Plans

I assist clients with the successful implementation and operation of various types of retirement plans, including pension, profit-sharing, 401(k) and 403(b) plans. I draft plan documents and summary plan descriptions, respond to plan documents and operational failures through the Internal Revenue Service’s Employee Plans Compliance Resolution System and counsel retirement plan committees on their fiduciary responsibilities under ERISA. My experience also includes advising individuals on the tax and estate planning implications of retirement plans and executive compensation arrangements.

Executive Compensation

I have experience helping clients on issues related to non-qualified deferred compensation plans, supplemental executive retirement plans and severance plans. I have also worked with clients to draft employment agreements for their executives.


I prepare privacy response plans for companies seeking to protect themselves against the threat of possible data breaches and create privacy policies for companies to ensure the safe storage and usage of the personal information of employees and customers. I also advise clients in the aftermath of a privacy breach by explaining the regulatory framework of the data privacy laws while helping to craft a practical and cost-efficient response plan.

What do you see on the horizon?

With the advent of numerous emerging technologies, attorneys need to not only be able to respond to client needs, but predict potential conflicts and complications. Attorneys must proactively advise and responsively advocate.

Prior to joining the firm

At Syracuse Law, Jenny was Business Editor of Syracuse Law Review, on the Moot Court Honor Society and a member of the Justinian Honorary Law Society. She is a member of the Syracuse Law’s Chapter of the Order of the Coif and a recipient of the CALI (Constitutional Law) and the Cornelius W. Wickersham Jr. Awards.


  • “Cybersecurity Takes a Village: Governance, Legal, and Cyber Perspectives,” 2019 NY Tech Summit, Turning Stone Conference Center, Verona, NY

Cybersecurity and benefits plans: The next front in the ongoing battle to protect personal information

Confero | June 30, 2018

Rochester Corporate group associate Jenny Holmes contributed this article to the quarterly magazine for Westminster Consulting, discussing why benefit plans are inviting targets for would-be data thieves, and what plan administrators need to do to protect personal data.

European Union law on data protection takes effect

Rochester Business Journal | June 07, 2018

Rochester corporate group partner Jeremy Wolk and associate Jenny Holmes co-wrote this contributed article on the introduction of the General Data Protection Regulation, “a set of tougher rules designed to give European Union citizens more control over their personal data.” The regulation applies to all organizations, regardless of location, that handle the personal data of EU citizens.

The Delayed Final Rule and Disability Claims Procedures: Are You Ready? Do You Have to Be?

Journal of Compensation and Benefits | March 19, 2018

Labor and employment associates Claire Rowland and Jenny Holmes authored this article about key changes and impact of the U.S. Department of Labor’s updated regulations for required disability claims procedures (Final Rule) going into effect on April 1, 2018.

Partial delay of fiduciary rule leaves investment industry in limbo

Pensions & Investments | December 06, 2017

Rochester labor and employment partner Christian Hancey and associate Jenny Holmes co-wrote this article on the Department of Labor’s new fiduciary rule regulations.

Before acquiring a firm, check its cybersecurity setup

Rochester Business Journal | March 16, 2017

Rochester private equity and investment funds partner Jeremy Wolk and labor and employment associate Jenny Holmes co-authored this column about cybersecurity due diligence.

Employees' smartphones threaten company security

Rochester Business Journal | January 19, 2017

Chief Information Officer Mike Green and Rochester labor and employment associate Jenny Holmes are quoted in this article about data protection issues surrounding bring your own device policies.

No immunity from cyberattacks and data breaches in 2016 and beyond

Rochester Business Journal | January 12, 2017

Rochester private equity and investment funds partner Jeremy Wolk and labor and employment associate Jenny Holmes co-authored this column about cyber security. The column provides an overview of the risks and potential legislative changes that could help small businesses and tips for creating a privacy policy.


Jenny L. Holmes



Phone: 585-263-1494

Syracuse University College of Law, J.D., Order of the Coif, magna cum laude

University of Virginia, B.A., American Government

New York

U.S. District Court, Western District of New York

U.S. District Court, Northern District of New York

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