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Client Alert

Treasury Issues New TARP Compensation and Governance Standards

June 24, 2009

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Because of the rapidly changing conditions in the financial markets, we have established this special series of Client Alerts to advise you of the newest economic and legal developments and their wide-ranging business implications.

Indicates Support For Related Legislation Affecting All Publicly Traded Companies

Earlier this month, the Treasury Department published an interim final rule which consolidates and updates Treasury's guidance to federal bailout recipients on executive compensation and corporate governance matters. In addition, with ramifications extending to all public companies and not just federal bailout recipients, Treasury Secretary Tim Geithner at the same time indicated that Treasury will support "say on pay" legislation, which would authorize the SEC to require annual non-binding shareholder votes on compensation for executives of publicly traded companies, as well as legislation that would direct the SEC to issue rules that would enhance the independence of public company compensation committees.

Click here to read our client alert on the recent Treasury executive compensation developments.

If you have any questions regarding these recent developments, please contact either the Womble Carlyle attorney with whom you usually work, one of our Employee Benefits attorneys or one of our Corporate and Securities attorneys listed on the following webpages.

Employee Benefits attorneys

Corporate and Securities attorneys

Womble Carlyle client alerts are intended to provide general information about significant legal developments and should not be construed as legal advice on any specific facts and circumstances, nor should they be construed as advertisements for legal services.

IRS CIRCULAR 230 NOTICE: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. tax advice within this client alert is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed in a client alert.