Compensation Provisions in the American Recovery and Reinvestment Act of 2009
Client Memorandum

Created date


Today, the President is expected to sign into law the American Recovery and Reinvestment Act of 2009, commonly referred to as the stimulus bill. This new legislation contains provisions relating to compensation paid by institutions that receive government assistance under TARP, including institutions that have already received such assistance. These provisions include restrictions on the amounts and forms of compensation payable, provision for possible reimbursement of previously paid compensation and a requirement that compensation be submitted to non-binding “say on pay” shareholder votes.