Earlier this month, six federal agencies each released a re-proposal of rules (the New Rules) on incentive compensation reforms under Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

The New Rules from the Office of the Comptroller of the Currency, the Federal Reserve System, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the National Credit Union Administration and the Securities and Exchange Commission (SEC) (collectively, the Agencies) build on rules proposed in 2011, but they go much further. The New Rules proposed by each Agency are largely similar, with differences chiefly related to the entities regulated by the Agencies, though the SEC rules differ with respect to treatment of subsidiaries, as discussed below.