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The Pay Czar’s Ruling on Compensation Practices for Companies that Received “Exceptional Assistance”


On October 22, 2009, the Special Pay Master for Executive Compensation (Special Pay Master) issued Determination Memorandums to each of the seven companies that received “exceptional assistance” under the Troubled Asset Relief Program (TARP). The memorandums addressed the proposed compensation payments and structures for the Senior Executive Officers (SEOs) and certain most highly compensated employees (HCEs) at each of the seven companies. We have summarized the Pay Czar’s guidance on executive compensation and corporate governance practices, and identified the potential implications of his rulings.

The Special Pay Master’s determinations with respect to the executive compensation and corporate governance structures of the seven companies receiving “exceptional assistance” will have profound implications on employee talent throughout the financial services Industry. We expect that the restrictions on base salaries, incentive compensation and performance measures may lead to a talent drain at those companies that have received the highest amount of Federal Government assistance.

Download the attached article below to learn more about these new rulings and the potential implications for financial services organizations.

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