Treasury Department Issues Final TARP Executive Compensation Guidance

On June 10th, Treasury released an Interim Final Rule providing guidance on the executive compensation and corporate governance provisions in the Emergency Economic Stabilization Act of 2008 ("EESA"), as amended by the American Recovery and Reinvestment Act of 2009.  Since the enactment of EESA in October of 2008, both Congress and the Obama Administration have provided piecemeal guidance on the executive compensation restrictions that apply to companies participating in the troubled asset relief program ("TARP").

On the same day that the Interim Final Rule was released, Treasury announced that it will pursue two pieces of executive compensation legislation that would apply to all public companies.

The attached memo summarizes the Interim Final Rule and the proposed legislation.

Read the Memo