September 8, 2009
Treasury Issues FAQs on its Interim Final Rules on TARP
– Arthur Kohn, Cleary Gottlieb Steen & Hamilton
On August 28th, Treasury issued these FAQs on the Interim Final Rule on TARP that it released back on June 15th. This memo sets forth our analysis of the effect of the FAQs, informed by informal conversations with Treasury, on a TARP recipient that repays its obligation prior to the deadline for forming a compensation committee.
By the way, check out our new “Say-on-Pay Resource Center,” which is intended as a convenient one-stop location for our client alerts, as well as legislative, regulatory and other materials on the topic. Thanks to the executive compensation team at Cleary Gottlieb – Brick Susko, Janet Fisher, Mary Alcock and Katie Sykes – for helping to man this fort!