Six federal agencies proposed bonus payment deferral and claw-back arrangements for certain large financial institutions and certain of their most senior officers (including, potentially, chief compliance and chief legal officers), as well as employees who expose their firms to large risk, if they receive incentive-based compensation. In general, the compensation rules would apply only to covered financial institutions that maintain consolidated assets in excess of US $1 billion, while the most onerous requirements, would apply solely to covered firms with consolidated assets in excess of US $250 billion. Impacted institutions could include certain banks, broker-dealers (but apparently not future commission merchants), credit unions and investment advisers. The rules were proposed jointly by the National Credit Union Administration, Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Securities and Exchange Commission. Under the proposed rules issued by the NCUA (the only agency that formally published its proposed rules as of April 22, 2016; however, NCUA’s proposed rules should be similar to those of the other agencies) the biggest firms would be required to defer a substantial portion of the incentive-based bonuses of senior executives (60 percent) and significant risk takers (50 percent) for four years and require the claw-back of previously paid bonuses for up to seven years if it is later determined that the senior executive or significant risk taker engaged in misconduct that “resulted in significant financial or reputational harm to the covered institution, fraud, or intentional misrepresentation of information used to determine the [covered person’s] incentive-based compensation.” The compliance date for the proposed rule, if adopted, would not be until the first calendar quarter that begins at least 540 days after a final rule is published. The proposed rules would also impose compensation arrangements’ oversight and approval requirements on boards of directors of covered institutions, and record-keeping requirements. The six federal agencies previously proposed similar compensation rules in 2011. Comments will be accepted on the proposed rules through July 22, 2016.