News & Analysis as of

Incentive Compensation Banking Sector

Cadwalader, Wickersham & Taft LLP

Amid Chaos, Regulatory Change Continues Apace, March 2025 - Change Has Arrived

We have written in prior Cabinet News & Views articles that, since the November elections, the U.S. federal banking regulators have been signaling significant changes in approach. This week, the FDIC kicked off the changes by...more

Latham & Watkins LLP

The Story Of 2024's Biggest Bank Regs, And Their Fate In 2025

Latham & Watkins LLP on

In 2024, the U.S. federal bank regulators were extremely active, with initiatives ranging from antitrust and capital to proposals regarding controlling shareholders and incentive-based compensation. Climate issues and...more

Troutman Pepper Locke

Revisiting Financial Institution Incentive Compensation Rules Under Dodd-Frank — The Consumer Finance Podcast

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In this episode of The Consumer Finance Podcast, Chris Willis delves into the renewed focus on incentive compensation by federal financial regulators. Joined by colleagues Sheri Adler and Jina Davidovich from the Employee...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2024

Headlines 1. Supreme Court Upholds the Constitutionality of the CFPB’s Funding Structure The Supreme Court has ruled that the statutory authorization that allows the CFPB to draw funds from the earnings of the Federal Reserve...more

Venable LLP

Irregular Time - A Quasi-Proposed Rule on Incentive-Based Compensation

Venable LLP on

For the third time, federal agencies have issued a proposed rule to regulate incentive-based compensation paid by certain financial institutions and other entities (the 2024 Proposal). The 2024 Proposal has been released by...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Third Attempt: Banking Agencies Revive Incentive-Based Compensation Rules for Financial Institutions

The Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and the National Credit Union Administration (NCUA) recently re-proposed rules...more

McGuireWoods LLP

(Some) Banking Agencies Repropose Dodd-Frank 956 Incentive Compensation Rules

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Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires that six agencies — the Federal Reserve System (FRS), Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance...more

Ruder Ware

Examiners are Carefully Scrutinizing Financial Institutions’ Compensation Arrangements

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It has come to our attention that some examiners have recently been carefully scrutinizing financial institutions’ employee compensation arrangements. Although it now appears unlikely that the proposed Dodd-Frank rules on...more

Thomas Fox - Compliance Evangelist

Sunshine Superman – When Culture is Not My Problem

Today we honor folk-rocker Donovan and his signature song Sunshine Superman, which was profiled in the Wall Street Journal (WSJ) column Anatomy of a Song. The song was a love paean by the singer to “Linda Lawrence, his love...more

The Volkov Law Group

Wells Fargo’s Desperate Need for a Compliance and Business Ethics Function (Part III of III)

The Volkov Law Group on

While reading the independent directors’ report on the Wells Fargo sales incentives scandal, you will be overwhelmed by the feeling of frustration. At the same time, what is described in the report is the extent to which...more

Alston & Bird

CFPB Focuses on Incentive-Based Compensation Programs

Alston & Bird on

Incentive-based compensation programs have long been a focus of banking regulators, but recent actions suggest that the issue is back at the top of the regulatory watch list. Specifically, action by the Consumer Financial...more

Bilzin Sumberg

CFPB Steps Up Oversight of Companies’ Compensation Programs Following Wells Fargo Scandal

Bilzin Sumberg on

The Consumer Financial Protection Bureau (CFPB) will likely be weakened by the incoming Trump administration and its Republican allies in Congress. Exactly how, and how much, remains to be seen, however—and, in the meantime,...more

Stinson - Corporate & Securities Law Blog

CFPB Outlines Expectations on Incentive Compensation

The CFPB issued a bulletin warning supervised financial companies that creating incentives for employees and service providers to meet sales and other business goals can lead to consumer harm if not properly managed....more

Ballard Spahr LLP

CFPB issues bulletin on incentive programs

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The CFPB has issued a new compliance bulletin (2016-03) on incentive programs. The issuance of the bulletin reflects the CFPB’s increased focus on such programs. In the bulletin, the CFPB acknowledges that incentives...more

The Volkov Law Group

After Circling the Wagons: Wells Fargo’s CEO Finally Falls

The Volkov Law Group on

The Wells Fargo scandal represents a textbook case of compliance and culture failures. Recently, the scandal and Wells Fargo’s defensive crisis management strategy resulted in CEO Stumpf’s resignation. Stumpf’s demise was...more

Thomas Fox - Compliance Evangelist

Wells Fargo Week, Part III-the Bank Knew All Along

You know it is going to be a very bad day when, as a company’s Chief Executive Officer (CEO), you receive a letter asking the following, “Specifically, the committee should thoroughly examine this issue, including: How it is...more

Thomas Fox - Compliance Evangelist

Wells Fargo Week: Part I – Who’s Afraid of Virginia Woolf or What is Risk?

Edward Albee died last week. To my mind he was right up there with Arthur Miller and August Wilson as one of America’s greatest playwrights of the second half of the 20th century. His works were known, as noted in his New...more

Ballard Spahr LLP

New Incentive-Based Compensation: Proposed Rules for Financial Institutions

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A group of financial regulatory agencies has released for comment revised proposed rules under Section 956 of the Dodd-Frank Act Wall Street Reform and Consumer Protection Act. The rules provide for regulations and guidelines...more

Troutman Pepper Locke

Reports Emanate From Washington That Financial Regulators Poised To Promulgate New Restrictions On Community Bank Executive...

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In June of 2010 bank regulatory agencies issued final guidance relating to incentive compensation arrangements at all financial institutions. Shortly thereafter in July, President Obama signed into law the Dodd-Frank Act....more

Stinson - Corporate & Securities Law Blog

Fed Governor Says Volcker Rule Thresholds Should be Raised

In testimony before a Senate committee, Federal Reserve Governor Daniel K. Tarullo suggested the threshold for the Volcker rule should be raised. He noted the Volcker rule and the incentive compensation requirements of...more

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