All TARP recipients remain subject to the general executive compensation restrictions under EESA and Treasury’s IFR. Annually, the CEO and CFO of each TARP recipient submit to Treasury certifications of compliance with the restrictions under the IFR. The Office of the Special Master exercises interpretive authority over the IFR as it applies to all TARP recipients.
As of May 2012, there are three exceptional assistance recipients—AIG, Ally Financial, and GM—that remain subject to the authority of the Special Master for exceptional assistance recipients. Four of the original seven recipients of exceptional assistance—Bank of America, Citigroup, Chrysler Financial, and Chrysler—have exited TARP.
The Office of the Special Master continues to review compensation structures for the top 100 employees at the remaining exceptional assistance recipients, including issuing determinations that set compensation amounts for the top 25 employees at each of those companies, all of which are available to the public [link to letters?]. The Office of the Special Master has been effective at limiting compensation at the seven companies over which it had authority, while ensuring the companies were well-positioned to pay back the taxpayers’ investments.
Achievements of the Office of the Special Master:
- OSM cut average cash compensation for the top 25 executives at the seven companies that received exceptional TARP assistance by more than 90 percent.
- OSM reduced average total compensation for the top 25 executives at the seven companies by more than 50 percent.
- Overall, more than 80 percent of compensation for the top 25 executives at the covered firms was payable in the form of stock-based compensation. This helps ensure that compensation is tied to long-term performance.
- More than three-quarters of the funds disbursed or committed to the firms OSM oversaw through TARP and, in the case of AIG, the Federal Reserve Bank of New York, has already been returned to the taxpayers.
- Four of the seven companies that received exceptional assistance—Bank of America, Citigroup, Chrysler Financial, and Chrysler—have exited TARP entirely.
And the Treasury has already begun exiting its investments in Ally Financial, AIG, and GM.