You first need to determine what your objectives are, change in control,change of heart of future management,change in financial condition or bankrupcy. The most prevalent is a "funded" Rabbi Trust" (see
http://www.crgworld.com under publications for a survey). I have found that most people do not follow the model trust rules, but rely on some 300 private letter rulings with such provisions as the "haircut" etc. If you attempt to cover bankrupcy, there are a number of concepts that are used, however they are based on legal opinions. The secular trust was used by many companies, however it is not prevalent today. Some used spit dollar, which I think wasn't the right tool, but now need to re-look at the arrangements. Our organization designed the Secured Trust, and have installed 14 of them, with two prevailing in bankrupcy court. I think we may have some details on this under our Executive Topics list on the web site.