On June 21, 2010 the banking regulatory agencies jointly issued the Final Guidance on Sound Incentive Compensation Policies (SICP) which applies to all banking organizations.  Amalfi Consulting offers an SICP Review service to help you navigate this new regulation.  Our review process was developed from a broad range of TARP Risk Reviews conducted for our clients. From this experience, we can make your review as efficient and effective as possible.  We will create an audit file that will allow your bank to monitor your plans on an on-going basis.  Your individual incentive plans and applicable employment and benefit agreements will be evaluated against 27 risk evaluation standards. These standards include plan documentation, general plan design, performance metrics, termination provisions, and equity plan design considerations.  We will also examine the processes used to evaluate incentive plans and agreements according to the three principles presented in the SICP: balanced risk-taking incentives, effective controls and risk management, and strong corporate governance.  Our analysis will help ensure that your bank is prepared for its next regulatory exam.

For additional information, please refer to our July 2010 Client Alert.

Attachments:

Client Alert: Sound Incentive Compensation Regulatory Guidance July 1, 2010