Dodd-Frank Act, Section 956

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U.S. financial regulators have recently re-proposed rules for Section 956 of the Dodd-Frank Act that would apply to incentive-based compensation at certain financial institutions. In addition to the rules that would apply to all with $1 billion or more, under the proposed rules, financial institutions with $50 billion or more in total consolidated assets would be required to subject incentive-based compensation for certain executives and significant risk-takers to: deferral of payment, risk of downward adjustment and forfeiture, and clawback. Semler Brossy has prepared an overview of the proposed rules and regulations.