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Are You a 'Significant Risk-Taker' Under Dodd-Frank?
Winston & Strawn LLP
[Guidance Overview] Apr. 27, 2016 "[B]eing labeled a 'significant risk-taker' in the new proposed rules under Dodd-Frank Act Section 956 just means you are subject to a mandatory compensation 'deferral' period during which up to 50% of your incentive-based compensation is subject to forfeiture or 'downward adjustment' (and after that, the compensation is subject to a clawback!). The definition of 'significant risk-taker' in the proposed rule is 20 pages long. It is intended to include 'covered persons' ... who are not 'senior executive officers' ... but are in the position to put a Level 1 or Level 2 covered institution at risk of material financial loss." MORE >> |
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