Executive Compensation

Program Overview

All TARP recipients are subject to executive compensation restrictions as long as their obligations to the Treasury are outstanding. The Emergency Economic Stabilization Act of 2008 (EESA), as amended by the American Recovery and Reinvestment Act of 2009 (ARRA), required that the Secretary of the Treasury issue standards governing executive compensation at financial institutions that received assistance under TARP.

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Key Facts

  • All TARP recipients are subject to the executive compensation restrictions under EESA and Treasury’s Interim Final Rule for TARP Standards for Compensation and Corporate Governance (IFR) until they have fully satisfied their obligations to the Treasury and exited the program.
  • The Office of the Special Master was established to ensure that executive compensation at financial institutions receiving exceptional assistance from the Treasury is structured and paid in a manner consistent with shareholder and taxpayer interests.
  • The Special Master reviews and approves any payment of compensation to the five senior executive officers and 20 next most highly paid employees at the companies receiving “exceptional assistance” from Treasury, and reviews and approves the structure of compensation for all employees who are executive officers or one of the 100 most highly compensated employees.

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