In Focus

CII Files Comment Letter on Dodd-Frank Rulemaking on Banker Bonuses

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.    

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Universal Proxy In contests, investors should be free to vote for the nominees they prefer.

Executive Compensation CEO pay should be transparent and tied to long-term performance.

Dual-Class Stock Each share of a public company's common stock should have one vote.

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