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Treasury Issues Compensation Standards For TARP Participants

Client Alert | 1 min read | 06.23.09

Treasury has issued an interim final rule, effective June 15, providing detailed compensation and corporate governance standards applicable, with a few limited exceptions, to any entity that has received or will receive financial assistance under TARP, any entity of which a TARP recipient owns at least 50%, and any entity which owns at least 50% of a recipient of TARP assistance.  Superseding the October 2008 interim rules, these regulations set standards in numerous areas, including (i) limits on compensation for senior executive officers, (ii) provision for the recovery of bonuses in the case of inaccurate statements of earnings, (iii) prohibition on golden parachute payments, (iv) adoption of an excessive or luxury expenditures policy, and (v) establishment of a compensation committee comprised of independent directors.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....

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