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ARTICLE · 31 OCTOBER 2008

U.S. Treasury Provides Interim Guidance On Executive Compensation Provisions In Emergency Economic Stabilization Act

The interim guidance provides important details about permitted executive compensation practices for financial institutions participating in the Troubled Asset Relief Program.

United StatesStrategy

The interim guidance provides important details about permitted executive compensation practices for financial institutions participating in the Troubled Asset Relief Program; other companies should also consider this guidance when working with their compensation committees regarding potential further executive compensation and corporate governance reform.

On October 14, 2008, the U.S. Department of Treasury issued interim guidance regarding the executive compensation restrictions under the Emergency Economic Stabilization Act (EESA) that apply to financial institutions participating in the Troubled Asset Auction Program, the Capital Purchase Program and Programs for Systematically Significant Failing Institutions. For more information, click here. The type and level of executive compensation restrictions vary significantly among these programs, particularly with respect to severance benefits. None of these restrictions apply to entities that do not participate

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