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Client Alert | May 2016

Dodd-Frank Section 956 Redux: Incentive Compensation at Financial Institutions Subject to Yet Another Set of Proposed Rules

A new set of proposed rules under Section 956 of the Dodd-Frank Act affects certain banking institutions and replaces an earlier 2011 proposal.

Incentive Compensation at Financial Institutions Subject to Yet Another Set of Proposed Rules

Section 956 of the Dodd-Frank Act was initially addressed in 2011 in a set of proposed, but never finalized, rules.

This client alert covers a replacement proposal of rules regulating the use of incentive-based compensation arrangements (ICAs) for certain financial institutions and outlines those points that are a continuation of the 2011 proposal, as well as the key changes. 

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