The Advisors' Blog

This blog features wisdom from respected compensation consultants and lawyers

September 29, 2025

Reg Flex Agenda: RIP (For Now) to Dodd-Frank Rules for Bank Incentive Compensation

As Meredith (and John) recently blogged, SEC Chair Paul Atkins has an ambitious list of priorities in the latest Reg Flex Agenda. This Gibson Dunn memo also points out what’s *not* on the agenda – specifically:

Certain Dodd-Frank-mandated rulemakings were dropped from short-term rulemaking and moved to long-term rulemaking in the 2025 Agenda, such as an interagency rulemaking intended to implement Section 956 of Dodd-Frank, which relates to incentive-based compensation practices at certain financial institutions that have $1 billion or more in total assets.

The Gibson Dunn team notes that four of six federal financial regulators re-proposed the Section 956 rule last year. Two of six, the SEC and the Federal Reserve, did not join in the issuance of the re-proposed rule – Meredith shared at the time that then-Commissioner Jaime Lizárraga was disappointed that the SEC didn’t jump on board.

Although the rule has made appearances on past Reg Flex Agendas, it’s not too surprising that it will remain “unfinished business” for now, given how issuer-friendly the Chair’s priorities appear to be.

Liz Dunshee

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