Davis Polk Discusses RECOUP Act’s Clawbacks of Failed-Bank Executives’ Compensation
Reynolds Holding
APRIL 10, 2024
The provision would grant the FDIC authority to recoup up to two years of compensation from any senior executive of a failed bank or a parent holding company who was responsible for the bank’s failed condition. Natural Resources Defense Council , 467 U.S. 2 See Chevron v. 837 (1984). 37, 1791 N.Y.
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