Regulatory Practice Letter October 2011 RPL 11-23

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1 Regulatory Practice Letter October 2011 RPL Fed Report on Incentive Compensation Arrangements Horizontal Review Results Executive Summary In late 2009, the Federal Reserve Board ( Fed ) initiated a horizontal review of incentive compensation practices at 28 large, complex banking organizations ( LCBOs ). On October 5, 2011 the Fed released a report summarizing the findings from this review, entitled Incentive Compensation Practices: A Report on the Horizontal Review of Practices at Large Banking Organizations ( Review Report ). Broadly, the review focused on the range of compensation practices across the firms and the categories of employees affected by these practices. The review also served to guide the LCBOs in their implementation of the Interagency Guidance on Sound Incentive Compensation Policies ( Interagency Guidance ) published by the Fed and the other bank and thrift regulators (Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation and Office of Thrift Supervision) in June The Review Report concludes that collectively the LCBOs subject to the review (25 were ultimately included in the final report, one-third of which are headquartered outside of the U.S ( Foreign LCBOs )) have made significant progress toward enhancing their incentive compensation arrangements to provide appropriately balanced incentives to take risks and to promote safety and soundness. The Review Report also concludes that most LCBOs still have significant work to do to achieve full compliance with the Interagency Guidance. Background In October 2009, the Fed proposed Guidance on Sound Incentive Compensation Policies ( Guidance ), which was intended to ensure that incentive compensation arrangements at financial organizations accounted for risk and were consistent with safe and sound practices. The Fed initiated the LCBO horizontal review simultaneously with the release of the proposed Guidance, focusing on incentive compensation arrangements and related risk management, internal controls and corporate governance practices. The other bank and thrift regulators joined the Fed in the release of the final version of the Guidance (the Interagency Guidance), which then became applicable to all of the banking organizations supervised by the four agencies on June 25, The Interagency Guidance is consistent with the Financial Stability Board s ( FSB ) Principles for Sound Compensation Practices issued in April 2009 and with the FSB s related Implementation Standards, which were issued in September 2009 (together FSB Principles and Standards ).

2 The Interagency Guidance provides that incentive compensation arrangements must meet three key principals to be consistent with safe and sound practices: 1. Provide employees incentives that appropriately balance risk and reward; 2. Be compatible with effective controls and risk-management; and 3. Be supported by strong corporate governance, including active and effective oversight by the organization s board of directors. In addition, the Interagency Guidance is applicable to the incentive compensation arrangements of covered employees, which include: Senior executives and others who are responsible for oversight of the organization s firm-wide activities or material business lines; Individual employees, including non-executive employees, whose activities may expose the organization to material amounts of risk (e.g., traders with large position limits relative to the organization s overall risk tolerance); and Groups of employees who are subject to the same or similar incentive compensation arrangements and who, in the aggregate, may expose the organization to material amounts of risk, even if no individual employee is likely to expose the organization to material risk (e.g., loan officers who, as a group, originate loans that account for a material amount of the organization s credit risk). At the same time the Fed announced the LCBO horizontal review, it also announced a second review program focused on incentive compensation arrangements at banking organizations that are not considered large and complex. These reviews were to be conducted as part of the risk management reviews conducted during the banking organization s regular, risk-focused examinations. These reviews are tailored to reflect the scope and complexity of the organization s activities, as well as the prevalence and scope of the organization s incentive compensation arrangements. Description At the outset of the horizontal review, the Fed indicated that it expected each of the LCBOs subject to review to have demonstrated significant progress toward consistency with the Interagency Guidance during calendar year 2010, substantial conformance with the Interagency Guidance by the end of 2011 (affecting incentive compensation awards for the 2011 performance year), and full compliance thereafter. The Fed states that the LCBOs selected to participate in the horizontal review were chosen because flawed approaches to incentive compensation at these institutions are more likely to have adverse effects on the broader financial system and because of their extensive use of incentive compensation practices. The review considered incentive compensation practices and related risk management, internal controls and corporate governance practices. In addition, the review served to guide the LCBOs in their implementation of the Interagency Guidance. The Fed also conducted focused examinations of incentive compensation practices in trading and mortgage origination business lines at a number of the organizations to supplement its larger review and to evaluate specifically how incentive compensation programs were implemented at the line-of-business level. Following completion of the horizontal reviews, incentive compensation reviews will continue as part of the supervisory review process.

3 The Fed s Review Report is organized into the following three components, highlights of which are discussed in more detail below. Balancing Incentives. Risk Management Controls and Corporate Governance. International Context. Balancing Incentives The Interagency Guidance suggests that incentive compensation arrangements achieve balance between risk and financial reward when the amount of money ultimately received by an employee depends not only on the employee s performance, but also on the risks taken in achieving this performance. The following methods for balancing risks and rewards were considered in the review. Risk Adjustment Risk adjustments incorporate information about the risks an employee s activities may pose to an organization into decisions about the employee s total compensation awards. No LCBOs had a well-developed strategy to use risk adjustments at the outset of the review though all firms now employ some sort of risk adjustment for a least some employees. Progress is uneven across firms and within firms. Risk adjustments may be based on quantitative measures or qualitative judgments. In all cases, risk adjustments should consider likely losses under stressed conditions. Policies and procedures must be in place to guide the consistent use of judgment. All decisions should be documented and subject to ex post review. Next Steps: Firms are instructed to evaluate the effectiveness of 2011 risk adjustments in Deferred Compensation Deferred compensation arrangements defer the actual payout of a portion of an incentive-based award beyond the end of the performance period. The deferred amount may be adjusted for actual losses or other things related to the employee s performance that are realized or become better known during the deferral period. Deferred compensation guidance is generally limited to senior executives. Most firms assign deferral rates to employees using a fixed schedule. Senior executives are often treated separately and more strictly than other employees. The average deferral is more than 60 percent. The most common deferral period is three years. Most deferred compensation is paid in the form of stock, stock options and performance units. At the outset of the review, few firms adjusted deferred payouts to reflect risk outcomes made available during the deferral period. The firms now employ one of three styles of deferred compensation arrangements: Formulaic where the vesting percentage can be adjusted in direct relation to a measure of performance during the deferral period. Judgment where less than full vesting can be paid based on a judgment rather than a performance metric.

4 Hybrid where a specific trigger value of performance is set at the beginning of the deferral period and judgment is used to determine the vesting percentage if the performance is below the trigger amount. Clawback provisions make a limited contribution to balancing risk-taking incentives because they discourage specific behaviors but do not affect most riskrelated decisions and are not triggered by most risk outcomes. Next Steps: All firms must continue to improve their performance-based deferral arrangements. Other Methods In addition to risk adjustments and deferred compensation, the Interagency Guidance identifies the use of longer performance periods (more than one year) and reduced sensitivity of awards to short-term performance as methods to achieve balance between risk and incentives. The horizontal review found that: Both longer performance periods and reduced sensitivity awards were in use but not used universally. Multiyear assessments should be based on policies and procedures that give appropriate weight to poor outcomes due to past decisions. Dampening the sensitivity of incentives to measures of short-term performance and capping incentive compensation awards are not sufficient alone to balance risk-taking incentives. Next Steps: Firms are encouraged to actively monitor industry, academic and regulatory developments in incentive compensation practices and theory to identify new or emerging methods to balance risk and reward. Covered Employees Incentive compensation arrangements for all covered employees should be appropriately balanced for all types of covered employees. Firms need to identify the relevant types and severities of risks that are incentivized through incentive compensation arrangements to ensure that such risks are balanced. Under the Interagency Guidance, covered employees include: Senior executives; Other individual employees able to take or influence material risks; and Groups of similarly compensated individuals who in the aggregate can take or influence material risk. The horizontal review found: Some firms have yet to establish processes for identifying covered employees, especially groups of covered employees. Materiality thresholds used to identify covered employees can be complementary to other methods for identifying covered employees but commonly contain weaknesses. In particular, they: fail to capture the full extent to which an employee exposes the firm; fail to include employees who significantly influence risk-taking but do not make final risk decisions; and, ignore groups of similarly compensated employees. Foreign LCBOs must identify a larger number of covered employees for U.S. operations than are generally covered by their home-country supervisory requirements (pursuant to the FSB Principles and Standards).

5 Risk Management Controls and Corporate Governance The development and maintenance of balanced incentive compensation arrangements should be supported by risk-management processes and internal controls. Risk management and control personnel should be involved in the design, operation and monitoring of incentive compensation arrangements. At the outset of the review, risk management personnel had little or no role in incentive compensation decisions. Human resources and finance personnel were involved though risk associated with an employee s activities was generally not considered. All firms in the review now have risk management personnel involved in the design and decision-making process, though the extent and nature of their involvement varies. Where risk experts are intensely involved in decisions regarding the basic design and detail of incentive compensation programs, progress on balancing risk-taking incentives has been faster. Risk management personnel should be compensated in a manner that is independent of the financial performance of the lines of businesses they oversee. Firms should regularly review the design and implementation of their incentive compensation arrangements and systems to ensure they result in appropriate risk-taking and to correct deficiencies. Such efforts could be enhanced by: Internal reviews and audits of compliance with policies and procedures; Monitoring of results relative to expectations; and Simulating the allocation of awards before implementation. The firm s board of directors or its delegated committee should oversee the development and operation of the incentive compensation policies, systems and control processes, as well as monitor the effectiveness of efforts to balance risk. Since the outset of the review, firms have enhanced the role of the board in overseeing the incentive compensation system, and have increased the attention paid to risk-related aspects of the system. Compensation committee members should overlap with the risk and audit committee members. Reviews should include the results of monitoring and the results of any corrective actions. Next Steps. The risk controls and corporate governance portions of most firms incentive compensation systems continue to be under development and the Fed indicates that it will work with these firms to ensure the efficacy of the policies, procedures, monitoring and controls. International Context Although the Interagency Guidance is consistent with the requirements outlined in the FSB Principles for Sound Compensation Practices and the related Implementation Standards, the Fed indicates that the Interagency Guidance is actually more detailed and demanding in many respects. The review found that: Progress toward meeting the Interagency Guidance is similar for U.S. LCBOs and Foreign LCBOs, particularly with respect to the guidance on corporate governance and the role of risk-management and control personnel. Foreign LCBOs have had more difficulty in identifying covered employees in their U.S. operations. Risk adjustments have generally been concentrated only at the firmwide or

6 Regulatory Practice business-line bonus pool level. The numerical examples included in the FSB Principles and Standards have sometimes been used as a benchmark (60 percent or more for senior executives, 40 percent or more for other individual material risk takers, which are not the same as covered employees) and both U.S. LCBOs and Foreign LCBOs have deferral fractions at or above these benchmarks. Some European Union countries requirements for the pay structure of incentive compensation awards may affect the balancing impact of risk taking incentives. Commentary It has been practically two years since the Fed first released its proposed rule on incentive compensation arrangements and it is clear that the incentive compensation arrangements in place at LCBOs and other large financial institutions will be under significant scrutiny for quite a long time. Since the release of the Fed s proposal and the FSB s Principles and Standards, additional rulemakings and guidance related to incentive compensation have been released by a number of supervisory entities, including the Basel Committee on Banking Supervision and the Securities and Exchange Commission ( SEC ). Incentive compensation provisions were also included in the Dodd-Frank Wall Street Reform and Consumer Protection Act, and proposed implementing rules were released by seven agencies (the Fed, Office of the Comptroller Currency, Federal Deposit Insurance Corporation, Office of Thrift Supervision, National Credit Union Administration, SEC and Federal Housing Finance Agency) in April (Please refer to Regulatory Practice Letter 11-08). As proposed, the agencies joint rulemaking is intended to supplement existing guidelines including the Interagency Guidelines and will continue to be applied to larger organizations, but will not affect community banks. Although the horizontal review was designed to see what plans were in place at the largest institutions, it served to facilitate the implementation of the Interagency Guidance, and many changes have been made to the design of incentive compensation plans across the industry since the review began. However, the Fed notes that the nature and extent of remaining work varies across organizations and sometimes within organizations. It adds that achieving conformance with the interagency guidance depends on the successful build-out of systems and processes, achievement of intermediate implementation milestones, and successful completion of remediation plans. Even then, in many cases, it will be important for the firms to keep in mind that new systems and practices have not been fully tested by experience, so ongoing monitoring of these new systems and practices will be important. Contact us: This is a publication of KPMG s Financial Services Regulatory Practice Contributing authors: Hugh Kelly, Principal: Jon Greenlee, Managing Director: Earlier editions are available at: ublications/regulatory-practice-letters/pages/default.aspx ALL INFORMATION PROVIDED HERE IS OF A GENERAL NATURE AND IS NOT INTENDED TO ADDRESS THE CIRCUMSTANCES OF ANY PARTICULAR INDIVIDUAL OR ENTITY. ALTHOUGH WE ENDEAVOR TO PROVIDE ACCURATE AND TIMELY INFORMATION, THERE CAN BE NO GUARANTEE THAT SUCH INFORMATION IS ACCURATE AS OF THE DATE IT IS RECEIVED OR THAT IT WILL CONTINUE TO BE ACCURATE IN THE FUTURE. NO ONE SHOULD ACT UPON SUCH INFORMATION WITHOUT APPROPRIATE PROFESSIONAL ADVICE AFTER A THOROUGH EXAMINATION OF THE FACTS OF THE PARTICULAR SITUATION KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. The KPMG name, logo and cutting through complexity are registered trademarks or trademarks of KPMG International WDC

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