On July 15, CII submitted a comment letter
to six federal agencies jointly proposing to implement Section 956 of the Dodd-Frank Act. The proposal
would strengthen procedures and requirements pertaining to the design, implementation and oversight of incentive-based pay for executives and “significant risk takers” at financial institutions. It focuses on reducing conflicts of interest and improving recipients’ risk/reward calculus, and will especially impact those institutions with at least $50 billion in assets. The proposal introduces mandatory deferrals; guidelines for forfeiture, downward adjustment and clawback; and revisions to risk management controls. The deadline for comment is July 22, although several industry groups have appealed for an extension.