Deja Vu All Over (and Over) Again? Dodd-Frank’s Financial Institution Incentive Pay Rules Re-Proposed (But Not by the SEC)
![People sitting in front of a laptop](/sites/default/files/styles/fullscreen_4x3_767x575_1x/public/2024-08/Labor%20and%20Employment_Laptops.jpg?itok=lwRjBR2T)
It's strange enough that the proposal for financial institutions to limit incentive pay remains unimplemented 14 years after Section 956 of Dodd-Frank mandated it, but it's perhaps as strange that a group of banking regulators just re-proposed draft rules from 2016 and that the SEC is not among the agencies that re-proposed the rules. Then again, the Federal Reserve has not yet joined the re-proposal party either.
Recently, the FDIC, the Office of the Comptroller of the Currency, the Federal Housing Finance Agency and the National Credit Union Administration re-proposed the rules that were proposed in mid-2016, with limited changes. The SEC and the Federal Reserve Board were among the parties proposing the 2016 rules, as well as initial proposed rules in 2011 - but not this time.
The SEC does mention adopting rules under Section 956 on its latest rulemaking agenda; however, it's unknown if (or when) the SEC will act given that the rulemaking agenda is aspirational. Maybe the third (or more) time will be the charm for Section 956!
Print and share
Authors
Explore more in
Public Chatter
Public Chatter provides practical guidance—and the latest developments—to those grappling with public company securities law and corporate governance issues, through content developed from an in-house perspective. Subscribe 🡢