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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 | 3 min read | 04.14.26

DOJ’s False Claims Act Resolution Against IBM Signals Heightened Risk for Federal Contractors with DEI Programs

On Friday, April 10, 2026, the U.S. Department of Justice (DOJ) announced that International Business Machines Corporation (IBM) has agreed to pay just over $17 million to resolve allegations that it violated the False Claims Act (FCA) by failing to comply with federal anti-discrimination requirements incorporated into its federal contracts due to allegedly discriminatory diversity, equity, and inclusion (DEI) employment practices. This resolution marks the first FCA settlement secured by the DOJ under its Civil Rights Fraud Initiative, created in May 2025, and announced by then-Deputy Attorney General Todd Blanche as part of the administration’s coordinated efforts to target allegedly unlawful DEI practices. Per the agreement, the settlement is neither an admission of liability by IBM nor a concession by the United States that its claims are not well founded....

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