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 | 1 min read | 04.18.24
GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings
On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS). Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:
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Making the EU Courts More Efficient for Trade-Related Decisions
