September 10, 2013
Executive compensation has reached unprecedented levels for Chief Officers with no supporting evidence that warrants such compensation. Officers have conducted activities that are prohibited under the rules, regulations and obligations of financial,fiduciary, banking and securities laws. There has been evidence of widespread insider trading on non-public information of customers and a distributed denial of services toward those with inherent property rights associated with deceased customer estates held internally by Officers of BHCs, wholly owned subsidiaries (custodians) and affiliated traders/advisors. Evidence has shown that the officers of large complex institutions have hidden funds in their retirement accounts, established accounts for their wives and children and other activity inconsistent with their duty to notify and disclose. They have failed in performing due diligence a/o enhanced due diligence to locate customers a/o securityholders of unsecuritized debt of issuing banks. It is not always true that the accountholders cannot be located. I propose that there be clawbacks in executive compensation, to include past bonuses, because of non-performance, theft, fiduciary breach and as being implemental in the financial crisis by violating FCPA, FDCA, TILA, ECOA, mortgage fraud and other violations of securities and banking laws, regulations, statutes and supervisory directives.
(Attached File #1: executivecompensation-321a.pdf) (Attached File #2: executivecompensation-321b.pdf) (Attached File #3: executivecompensation-321c.pdf)