A QUESTION OF INCENTIVES

The Corrigan report, Containing Systemic Risk: The Road to Reform The Report of the CRMPG III, mentions 5 different problems that led to the Big ShitPile. Compensation incentives was one of them and that's not surprising since many of the MOTU responsible for the ShitPile still walked away with tens of millions of dollars.

Fifth: it is likely that flaws in the design and workings of the systems of incentives within the financial sector have inadvertently produced patterns of behavior and allocations of resources that are not always consistent with the basic goal of financial stability. Often, when the issue of incentives is discussed, the focus is oncompensation and, especially, executive compensation. Consistent with the priorities of this Report noted earlier, the Policy Group has chosen not go into the subject of executive compensation in any detail. Having said that, the Policy Group recognizes that more can be done to ensure that incentives associated with compensation are better aligned with risk taking and risk tolerance across broad classes of senior and executive management. Accordingly, and respecting the role and responsibilities of the board of directors in matters relating to executive compensation, the Policy Group believes that compensation practices as they apply to senior and executive management should be (1) based heavily on the performance of the firm as a whole and (2) heavily stock-based with such stockbased compensation vesting over an extended period of time. The long vesting period is particularly important for high risk, high volatility lines of business where short run surges in revenues and profits can be offset if not reversed in the longer term. In broad terms, the Policy Group recognizes that this philosophy of compensation is hardly new, but its importance looms especially large given the events of the past twelve months.

While the linkage between incentives and compensation is obvious for large integrated financial intermediaries, the incentive question has much broader – and no less important – implications. For example, the framework of incentives at the level of individual firms should help to balance business imperatives by ensuring that the resource base and the recognition/reward system for the support and control functions are such that critical tasks, such as risk monitoring and price verification, are performed in a manner that protects the financial integrity and professional reputation of the institution.