Proposed Rules on Incentive-Based Compensation Arrangements

SIFMA provides comments to the Office of the Comptroller of the Currency (OCC), the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), the Office of Thrift Supervision (OTS), and the Securities and Exchange Commission (SEC) on the proposed rules on Incentive-Based Compensation Arrangements (OCC Docket ID OCC-2011-0001; Federal Reserve Docket No. R-1410 and RIN No. 7100-AD69; FDIC RIN No. 3064-AD56; OTS Docket No. OTS-2011-0004; SEC File Number S7-12-11).  Although we support ensuring that incentive-based compensation arrangements are consistent with overall safety and soundness, we believe that a number of important clarifications and modifications are necessary in order to ensure that the proposed rules appropriately address this goal. SIFMA urges the regulators to consider the Executive Order in their assessment of the proposed rules and whether they achieve the goals of Section 956 of the Dodd Frank Act in an efficient and appropriate manner.