The Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and the National Credit Union Administration (NCUA) recently re-proposed rules on incentive-based compensation arrangements at certain financial institutions with at least $1 billion in assets (Proposed Rule). Among other things, the Proposed Rule would subject certain compensation to recovery for at least seven years after vesting if a “senior executive officer” or “significant risk-taker” (based on their relative level of incentive compensation or ability to expose financial assets to risk) engaged in misconduct that resulted in significant financial or reputational harm to the institution or committed other specified bad acts. READ MORE