On January 11, 2010, New York Attorney General Andrew Cuomo sent letters to each of the eight banks that first received funding under the federal government’s Troubled Asset Relief Program (TARP) as part of a broader investigation into executive compensation.

Among other things, Attorney General Cuomo has asked for:

  • a description of all bonus pools for 2009 (i.e., how such pools were established);
  • a description of the bank’s bonus program (including a breakdown of compensation and other incentives);
  • a description of how the 2009 bonus program differed from the 2008 program;
  • a description of how the bonus pools were allocated differently as a result of the bank’s receipt of TARP funds and/or the repayment of TARP funds;
  • a description of how the bonus pools would have been impacted had the bank not received TARP funding in 2008 and/or 2009;
  • a chart of the bank’s rate and degree of lending over the last 3 calendar years;
  • the total value of 2009 bonuses awarded;
  • the number of employees who received bonuses equal or greater to $1 million, $2 million, and $3 million; and
  • the number of employees at the bank as of December 31, 2009.

The above information has been requested by February 8, 2010.