The U.S. Treasury Department has published the Troubled Asset Relief Program (TARP) Standards for Compensation and Corporate Governance. While some changes may be made during this comment period, through mid-August, lawmakers expect it will pass.
Page 14 describes “a company-wide policy be put into place regarding excessive or luxury expenditures, as identified by the Secretary, and that may include excessive expenditures on entertainment or events.” (see below)
Page 56 describes excessive or luxury expenditures. It allows for reasonable expenditures on staff development, reasonable performance incentives or other similar reasonable measures conducted in the normal course of the TARP recipient's business operations. (see below)
In addition, it includes six steps to be in compliance.
Policies, approvals, processes, control and compliance are all required…components that I have highlighted in previous blogs. We have these templates in place NOW to help you. Don’t loose sleepless nights trying to recreate the wheel. Please contact me for assistance.
To see the entire document, navigate to:
http://www.treas.gov/press/releases/reports/ec%20ifr%20fr%20web%206.9.09tg164.pdf
Debi Scholar, CMM, CMP, CTE, CTT
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PAGE 14
Section 111(d) requires a TARP recipient’s board of directors to put in place a company-wide policy regarding excessive or luxury expenditures, as identified by the Secretary, and that may include excessive expenditures on entertainment or events, office and facility renovations, aviation or other transportation services, or other activities or events that are not reasonable expenditures for staff development, reasonable performance incentives, or other similar measures conducted in the normal course of the TARP recipient’s business operations.
PAGE 56
Excessive or luxury expenditures. The term “excessive or luxury expenditures” means excessive expenditures on any of the following to the extent such expenditures are not reasonable expenditures for staff development, reasonable performance incentives, or other similar reasonable measures conducted in the normal course of the TARP recipient’s business operations:
(1) Entertainment or events;
(2) Office and facility renovations;
(3) Aviation or other transportation services; and
(4) Other similar items, activities, or events for which the TARP recipient may reasonably anticipate incurring expenses, or reimbursing an employee for incurring expenses.
Excessive or luxury expenditures policy. The term “excessive or luxury expenditures policy” means written standards applicable to the TARP recipient and its employees that address the four categories of expenses set forth in the definition of “excessive or luxury expenditures” (entertainment or events, office and facility renovations, aviation or other transportation services, and other similar items, activities or events), and that are reasonably designed to eliminate excessive and luxury expenditures.
Such written standards must:
(1) Identify the types or categories of expenditures which are prohibited (which may include a threshold expenditure amount per item, activity, or event or a threshold expenditure amount per employee receiving the item or participating in the activity or event);
(2) Identify the types or categories of expenditures for which prior approval is required (which may include a threshold expenditure amount per item, activity, or event or a threshold expenditure amount per employee receiving the item or participating in the activity or event);
(3) Provide reasonable approval procedures under which an expenditure requiring prior approval may be approved;
(4) Require PEO and PFO certification that the approval of any expenditure requiring the prior approval of any SEO, any executive officer of a substantially similar level of responsibility, or the TARP recipient’s board of directors (or a committee of such board of directors), was properly obtained with respect to each such expenditure;
(5) Require the prompt internal reporting of violations to an appropriate person or persons identified in this policy; and
(6) Mandate accountability for adherence to this policy.
It's great to hear from you and see what you've been up to. This blog makes me realize the energy of words and pictures. Keep coming up with ideas.
Posted by: New Jordans | May 10, 2010 at 10:38 PM