The deadline for TARP CPP recipients who received capital infusions prior to June 15, 2009 are required to have adopted an Excessive or Luxury Expenditures Policy by Monday, September 14, 2009. In addition to adopting such a policy, TARP CPP recipients are required to submit the policy to Treasury and their primary federal banking regulator, and post the policy on their website. (Subsequent TARP CPP recipients are required to adopt and post a policy within 90 days after the completion of their capital infusion.)
We have collected a list of posted Excessive or Luxury Expenditure Policies. This list is complied for informational purposes only to offer examples, and is not intended to be complete list of posted policies. In addition, we may not identify when a bank has filed a revised policy. Inclusion (or exclusion) from the list does not represent a recommendation of any policy. Clients of Bryan Cave should contact us to further discuss an appropriate Excessive or Luxury Expenditures Policy.
The Buying and Selling of Distressed Notes
The volume of purchase and sale of performing and non-performing real estate loans has picked up dramatically over the past year as banks seek to shrink their balance sheets as their capital base falls and other banks and investors seek to take advantage of the sale of assets from failing banks. What are the typical features of such agreements and what are the interests of buyers and sellers in such transactions?
For more information, please read the client alert published by Bryan Cave LLP’s Real Estate Banking, Business and Public Finance Financial Institutions Client Service Group on August 5, 2009.
Group Health Plans: Compliance Items
Several important changes in governing law and regulations during the past year require changes to group health plans in the upcoming enrollment period. Below is a brief description of these major changes which require implementation in 2009 or 2010.
For more information, please read the client alert published by Bryan Cave LLP’s Employee Benefits & Executive Compensation Client Service Group on August 20, 2009.
New York Restaurant Employer Briefing — Wage Payment Requirements
New York restauranteurs operate in one of the most regulated employment environments in the country. In addition to the federal, state and local laws applicable to all employers, such as those prohibiting employment discrimination, governing the payment of wages, workplace safety and leaves of absence, New York-based restaurants also must comply with regulations applicable only to the restaurant industry. This extensive maze of regulation can be exploited by plaintiffs’ lawyers who search for unwitting violations. This has led recently to many lawsuits that are costly to defend, and which seek not only damages for employees, but also fees and costs for the attorneys who bring these suits. The threat of litigation is compounded by the fact that many lawsuits are brought as collective actions on behalf of several employees, which can greatly add to potential damages and to the complexity of the defense.
For more information, please read the client alert published by Bryan Cave LLP’s Labor and Employment Client Service Group on July 31, 2009.