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TARP LEGISLATIVE AND REGULATORY SUMMARY print email

The American Recovery and Reinvestment Act of 2009 (referred to as the Stimulus Bill) included strict and restrictive new limits on executive compensation for all Troubled Asset Relief Program (TARP) participants.

Amalfi Consulting has continued to follow TARP legislative and regulatory comment and clarification activity. 

We have produced a number of documents and webinar recordings in an effort to keep our clients educated about how TARP guidelines impact banks' executive compensation and incentive programs.  Below is the collection of these TARP documents and videos.

 

Webinar Recordings:

Initial analysis of TARP guidelines: March 10, 2009

2nd TARP webinar: June 26, 2009 Regulatory Update-TARP and Executive Compensation

3rd TARP webinar: July 16, 2009 TARP analysis - Decisions and Next Steps

 

In the 'Attachments' area located below you can find PDF documents of the presentation materials used in the above webinar recordings.

 

In November and December of 2009 the Administration offered  TARP Technical Corrections as well as SEC Proxy Disclosure guidelines in which Amalfi produced a webinar recording documenting the effect it might have on banks' SEC proxy disclosures and other pertinent matters.

SEC Proxy Disclosure & TARP Technical Corrections: December 28, 2009

 

TARP SPECIAL MASTER REVIEW

On March 23, 2010, the Special Master for TARP Executive Compensation issued formal requests for compensation data and certifications from over four hundred institutions that received financial assistance under the Troubled Asset Relief Program prior to February 17, 2009.  The data will be used by the Special Master to review all bonuses, retention awards and other compensation paid to the senior executive officers and the next 20 most-highly compensated employees during the period beginning with the date the TARP recipient fist received financial assistance and ending February 17, 2009. 

The named institutions have until April 22, 2010 to provided the data.

Amalfi Consulting has prepared a Client Alert summarizing the areas that the Special Master will be reviewing.  In addition, the Client Alert includes a number of clarification points that are the result of direct communication with Treasury on a number of matters.  You may find the Client Alert in the attachments area below.  Also attached, you will find the letter from the Special Master, instructions,  FAQs, and the Compensation Review Data Request  form  to fill out to comply with the request.

 

 
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