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ARTICLE · 28 MAY 2024

Irregular Time—A Quasi-Proposed Rule On Incentive-Based Compensation

Venable LLP
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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).

United StatesFinance and Banking
Max Bonici
Max Bonici

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 the FDIC, OCC, NCUA, and the Federal Housing Finance Agency. Section 956 of the Dodd-Frank Act, however, requires that six specific federal agencies issue a joint rule or guidance on incentive-based compensation. In the absence of the Federal Reserve and the SEC, the 2024 Proposal will not be published in the Federal Register for formal comment. The issuing agencies will accept comments on the draft version in the meantime. While the 2024 Proposal is not an actual proposal, entities that would be covered should note how the agencies' thinking on these issues may be evolving.

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