June 5, 2011
Elizabeth Murphy
100 F Street, NE
Washington, DC 20549
Dear Murphy,
Americans paid a terrible economic price because of irresponsible risk-taking by Wall Street executives. Those executives took those risks because they knew that they could walk away with billions of dollars in bonuses and stock options and never pay for the long-term consequences of their actions. We need tough rules so that Wall Street pay packages don't encourage short-term risk taking and legal prohibition from such irresponsible banking action. The rules now in place are inadequate and should be strengthened as follows:
1) A longer deferral period and/or more pay deferred -- Your rules should require at least a five year deferral period for executive bonuses at big banks and at least 50% of pay to be deferred: It should apply to the full range of important financial institutions, and draw in all the key executives at those companies.
2) Prohibit executive hedging of their pay packages making side deals to get most of their money today and get around the deferral rules.
3) Prohibit manipulative action by banks/financial institutions to devalue any individual company.
4) Include any investment offering which packages bank loans or other bank investments within the category of "insider trading".
Once this ruling is passed, only you will know the details of its enforcement. But it's important for the public to know the progress you are making on this vital issue. You should report back to the public annually with a detailed report on progress in creating accountability for Wall Street pay and banking responsibility.
Referencing Docket No.'s:
OTS: RIN 155-AC49
OCC: RIN 1557-AD39
Fed: RIN 7100-AD69
SEC: RIN 3235-AL06
FHFA: RIN 2590-AA42
FDIC: RIN 3064-AD56
Sincerely,
Mr. T.Ed. Webb