New TARP Executive Compensation Guidance and a Call for Further Reform in Executive Compensation Practices

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June 10,2009 marked an extraordinary day of announcements affecting executive compensation for both recipients of financial assistance from the Troubled Asset Relief Program (“TARP”) and other publicly held companies, including:

*The U.S. Department of the Treasury (“Treasury”) issued a statement outlining the Administration’s expectations and planned legislative proposals for executive compensation reform for publicly held companies.

*The Securities and Exchange Commission (“SEC”) announced it will soon be proposing new expanded compensation disclosure rules that could take effect in time for the 2010 proxy season.

*The Treasury issued regulations providing its much anticipated guidance on standards for executive compensation and corporate governance for TARP recipients.

*The Treasury established an Office of the Special Master for TARP Executive Compensation (the “Special Master”).

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Sheppard Mullin Richter & Hampton LLP on:

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