TARP
The Troubled Asset Relief Program (TARP) has significantly influenced the banking industry. Today, despite an organization’s status of participation in TARP, regulations have been trending to the requirements of these programs, thus creating “a spirit of TARP” compliance within the banking industry.
The effect on organizations is primarily centered on the composition of compensation, to include heavy weighting to restricted stock, and the application of risk assessments, specifically related to incentive compensation practices. Again, although these practices are not currently mandated, there is a trend to apply, at some level, these TARP requirements.
MCCA, since the inception of TARP, has worked with TARP recipients to ensure compliance. Furthermore MCCA has used our experience to implement similar practices into non-TARP institutions, which creates a ‘best-practices’ compliance structure.