ALERT – Impact of COVID-19 on Performance-Based Compensation – Key Considerations

December 21, 2020

To our clients and friends:

For many banks, the impact of COVID-19 on the financial performance has reduced or eliminated entirely the achievement of the 2020 performance-based compensation goals established before the breakout of the pandemic. As 2020 comes to an end, banks will need to evaluate the impact of COVID-19 on their performance-based compensation, specifically whether to adjust or eliminate performance goals to provide more realistic incentives for their executive officers and employees.

Our Alert, which is available here, provides an overview of key considerations for adjusting or eliminating performance goals in consideration of the effects of COVID-19.

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SEC Updates Guide 3 Statistical Disclosure Requirements

September 28, 2020

The Securities and Exchange Commission recently adopted new rules to update its statistical disclosure requirements for banking registrants, including domestic and foreign bank holding companies, banks, savings and loan holding companies, and savings and loan associations. The rules are contained in a new Item 1400 of Regulation S-K and will replace Industry Guide 3, Statistical Disclosure by Bank Holding Companies. These changes represent the first updates to Guide 3 in more than 30 years. Our Alert regarding this release is available here.

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