May 7, 2024
More On Financial Institution Incentive Compensation: Three Agencies Re-Propose Rule
It turns out the rumors were true. Yesterday, the FDIC, OCC and Federal Housing Finance Agency adopted a notice of proposed rulemaking to implement Section 956 of Dodd-Frank. According to this Sullivan & Cromwell memo, the re-proposed rule is generally consistent with the form proposed in 2016.
Keep in mind that the notice of proposed rulemaking will not be published in the Federal Register until all six agencies propose it, and the memo gives the status of the rule with each of the three remaining agencies:
– The National Credit Union Administration is expected to propose the same rule in the near future.
– The Securities and Exchange Commission has included a rulemaking to implement Section 956 of Dodd-Frank on its rulemaking agenda.
– The Board of Governors of the Federal Reserve System has not joined the FDIC’s, OCC’s and FHFA’s proposal.
Despite the delay in the formal comment period, the memo states that the FDIC, OCC and FHFA have each made the proposed rule text available on their websites and will accept comments. Take a look at the memo for a summary of key provisions.
– Meredith Ervine