Latest Restrictions on Compensation of Executives at Financial Institutions Receiving Assistance Under the Troubled Asset Relief Program


Overview of the latest developments

The American Recovery and Reinvestment Act of 2009 (“ARRA”) that became law on February 17, 2009, imposes new restrictions on compensation of certain executives at financial institutions that receive assistance under the Troubled Asset Relief Program (“TARP”) under the Emergency Economic Stabilization Act of 2008 (“EESA”). This is in addition to the compensation restrictions recently announced by the Treasury Dept. (“Treasury Guidelines”) in its February 4th press release ( press/releases/tg15.htm) covering executive compensation paid by those financial institutions (for example, Bank of America) receiving “exceptional financial recovery assistance”.

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