SIGTARP 13-001 January 28, 2013

Treasury Continues Approving Excessive Pay

for Top Executives at Bailed-Out Companies
Office of the special inspector general

 For the Troubled Asset Relief Program 

1801 L Street, NW, 4th Floor

Washington, D.C. 20220

SIGTARP 13-001 January 28, 2013

January 28, 2013

MEMORANDUM FOR: The Honorable Timothy F. Geithner – Secretary of the Treasury

FROM: Ms. Christy L. Romero – Special Inspector 

General for the Troubled Asset Relief Program

SUBJECT: Treasury Continues Approving Excessive Pay for Top Executives at

Bailed-Out Companies (SIGTARP 13-001)

We are providing this report for your information and use. It discusses Treasury’s 2012 

executive compensation decisions for Top 25 employees of American International Group, Inc., 

General Motors Corporation, and Ally Financial Inc.

The Office of the Special Inspector General for the Troubled Asset Relief Program conducted 

this evaluation (engagement code 003), under the authority of the Emergency Economic 

Stabilization Act of 2008 and Public Law 110-343, as amended, which also incorporates the 

duties and responsibilities of inspectors general under the Inspector General Act of 1978, as 

amended.

We considered comments from the Department of the Treasury when preparing the report. 

Treasury’s comments are addressed in the report, where applicable.

We appreciate the courtesies extended to our staff. For additional information on this report, 

please contact me or Mr. Bruce Gimbel, Acting Assistant Deputy Special Inspector General for 

Audit and Evaluation (Bruce.Gimbel@treasury.gov / 202-927-8978).
Treasury Continues Approving Excessive Pay for Top Executives

at Bailed-Out Companies

SIGTARP 13-001 January 28, 2013

Summary

When Congress passed the Troubled Asset 

Relief Program (“TARP”) and subsequent 

economic stimulus legislation, it placed 

limitations on executive compensation for 

TARP recipients, and left it to the U.S. 

Department of the Treasury (“Treasury”) to 

implement the limitations. Treasury created 

the Office of the Special Master for TARP 

Executive Compensation (“OSM”). 

Kenneth R. Feinberg served as the Special 

Master – often called the pay czar – and was 

succeeded by Patricia Geoghegan. OSM has 

jurisdiction over compensation at companies 

that stood out from the more than 700 TARP 

recipients because of the amount and nature 

of their exceptional bailout. OSM sets pay 

for Top 25 employees at these TARP 

exceptional assistance recipients.

In January 2012, the Office of the Special 

Inspector General for TARP (“SIGTARP”), 

issued a report finding that, from 2009 to 

2011, the Special Master could not rein in 

excessive compensation at the seven 

companies that received exceptional TARP 

assistance because he was under the 

constraint that his most important goal was 

to get the companies to repay TARP. 

SIGTARP reported that despite reducing 

some pay, OSM approved pay packages 

worth $5 million or more for 49 individuals. 

SIGTARP reported that OSM did not 

establish meaningful criteria for granting

exceptions to what Feinberg called 

“prescriptions” – that total compensation 

should target the 50th percentile for similarly 

situated employees at similarly situated 

entities and that cash salaries should not 

exceed $500,000, except for good cause. 

SIGTARP made recommendations for 

Treasury to improve these pay-setting 

processes.

SIGTARP initiated this evaluation to assess 

OSM’s pay-setting process for 2012 for Top 

25 employees of the remaining TARP 

exceptional assistance companies, AIG, 

GM, and Ally in light of the findings and 

recommendations in SIGTARP’s earlier 

report.

What SIGTARP Found

SIGTARP found that once again, in 2012, 

Treasury failed to rein in excessive pay. In 

2012, OSM approved pay packages of 

$3 million or more for 54% of the 69 Top 25 

employees at American International 

Group, Inc. (“AIG”), General Motors 

Corporation (“GM”), and Ally Financial 

Inc. (“Ally,” formerly General Motors 

Acceptance Corporation, Inc.) – 23% of 

these top executives (16 of 69) received 

Treasury-approved pay packages of 

$5 million or more, and 30% (21 of 69) 

received pay ranging from $3 million to 

$4.9 million. Treasury seemingly set a 

floor, awarding 2012 total pay of at least 

$1 million for all but one person. Even 

though OSM set guidelines aimed at curbing 

excessive pay, SIGTARP previously warned 

that Treasury lacked robust criteria, policies, 

and procedures to ensure those guidelines 

are met. Treasury made no meaningful 

reform to its processes. Absent robust 

criteria, policies, and procedures to ensure 

its guidelines were met, OSM’s decisions 

were largely driven by the pay proposals of 

the same companies that historically, and 

again in 2012, proposed excessive pay. 

With the companies exercising significant 

leverage, the Acting Special Master rolled 

back OSM’s application of guidelines aimed 

at curbing excessive pay.

The guidelines originally created by former 

Special Master Feinberg were aimed at 
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at Bailed-Out Companies

SIGTARP 13-001 January 28, 2013

fixing the material role executive 

compensation played in causing the 

financial crisis by encouraging excessive 

risk taking. By not holding the line on large 

cash salaries (awarding $500,000 or more to 

70% of the executives under OSM’s paysetting jurisdiction, and allowing 94% of 

employees to be paid cash salaries of 

$450,000 or more), and removing long-term, 

incentive-based stock as requested by the 

companies, OSM is effectively relinquishing 

some of OSM’s authority to the companies, 

which have their own best interests in mind. 

The Office of the Special Master’s job is to 

look out for the interests of taxpayers, which 

it cannot do if it continues to rely to a great 

extent on the companies’ proposals and 

justifications without conducting its own 

independent analysis.

Given OSM’s overriding goal to get the 

companies to repay TARP, as in prior years, 

the companies in 2012 had significant 

leverage over OSM by proposing and 

negotiating for excessive pay, warning that 

if OSM did not provide competitive pay 

packages, top executives would leave and go 

elsewhere. By proposing and negotiating 

for excessive 2012 pay, these executives 

continue to lack an appreciation for their 

extraordinary situations and fail to view 

themselves through the lenses of companies 

substantially owned by the U.S. Government 

(“Government”). For example, by the 

companies requesting pay raises for 18 

employees, the companies evidenced a lack 

of appreciation that they continued to be 

funded by taxpayers. GM CEO Dan 

Akerson even asked Treasury Secretary 

Geithner to relieve GM from OSM’s pay 

restrictions, which was denied.

OSM awarded $6.2 million in pay raises to 

18 of the 18 employees for whom the 

companies proposed raises. Treasury 

approved a $1 million pay raise for AIG’s 

CEO of its subsidiary, Chartis, a $200,000 

pay raise for an employee of its subsidiary, 

Residential Capital, LLC (“ResCap”) –

weeks before ResCap filed for bankruptcy –

and a $100,000 pay raise for an executive at 

GM’s European unit, despite that unit 

experiencing significant losses. OSM’s 

written explanations for the pay raises 

lacked substance, largely parroting what 

each company asserted to OSM without any 

independent analysis by OSM. 

In 2012, OSM did not follow its own 

guidelines aimed at curbing excessive pay 

by having total compensation generally not 

exceed the 50th percentile for similarly 

situated employees. Treasury awarded total 

pay packages exceeding the 50th percentile 

by more than $37 million for approximately 

63% of the Top 25 employees of AIG, GM, 

and Ally. The Acting Special Master 

appears to have rolled back the 50th 

percentile guideline, telling SIGTARP, for 

example, that she set total compensation for 

all of Ally’s Top 25 employees between the 

50th and 75th percentiles. 

Feinberg previously told SIGTARP that he 

limited cash salaries to $500,000 and shifted 

compensation more toward stock to reduce 

excessive risk and keep employees’ “skin in 

the game.” Feinberg testified before 

Congress that “base cash salaries should 

rarely exceed $500,000, and only then for 

good cause shown, and should be, in many 

cases, well under $500,000.” Never have 

there been so many exceptions to the 

$500,000 cash salary guideline for the 

number of people under the Acting Special 

Master’s jurisdiction as there was in 2012. 

The Acting Special Master increased the 

number of employees with Treasury-
Treasury Continues Approving Excessive Pay for Top Executives

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SIGTARP 13-001 January 28, 2013

approved cash salaries greater than $500,000 

from 22 employees in 2011 to 23 employees 

in 2012, a number that has quadrupled since 

2009. 

OSM also allowed 25 employees to have 

cash salaries exactly at the $500,000 limit. 

OSM allowed cash salaries of $500,000 or 

more for 70% (48 of 69) of Top 25 

employees at AIG, GM, and Ally. OSM 

allowed cash salaries of $450,000 or more 

for 94% (65 of 69) of Top 25 employees at 

AIG, GM, and Ally. In stark contrast, the 

2011 median household income of U.S. 

taxpayers who fund these companies was 

approximately $50,000.

Similar to OSM’s explanations for 

approving pay raises, OSM’s “justifications” 

for good cause for cash salaries to exceed 

$500,000 largely parrot what each company 

asserted to OSM without an OSM 

independent analysis. The Acting Special 

Master told SIGTARP that it would be 

“utterly normal” for these individuals in the 

Top 25 to expect over $500,000 in cash 

salary. That might be true if the companies 

had not been bailed out and were not still 

significantly owned by taxpayers. Acting 

Special Master Geoghegan said she did not 

think that when the $500,000 guideline was 

formulated, it would take an “independent 

little project” to determine when someone 

should go above $500,000. If the pay czar is 

not even willing to independently analyze 

high cash salaries for 23 employees, who 

else will protect taxpayers?

Feinberg testified before Congress that he 

used long-term restricted stock tied to 

performance metrics to correct problems 

with executive compensation practices at 

these companies. In 2012, the Acting 

Special Master removed long-term restricted 

stock from some executives’ pay and used it 

only in half of the pay packages, effectively 

removing a key OSM guideline aimed at 

reducing excessive risk by tying individual 

compensation to long-term company 

success. She also removed long-term 

restricted stock for senior executives, 

including the CEOs of AIG, GM, and Ally

There are two lessons to be learned from 

OSM’s 2012 pay-setting process and 

decisions:

First, guidelines aimed at curbing excessive 

pay are not effective, absent robust policies, 

procedures, or criteria to ensure that the 

guidelines are met. This is the second report 

by SIGTARP to warn that the Office of the 

Special Master, after four years, still does 

not have robust policies, procedures, or 

criteria to ensure that pay for executives at 

TARP exceptional assistance companies 

stays within OSM’s guidelines. Perhaps the 

Acting Special Master thinks that OSM has 

already succeeded in achieving its mission 

by limiting compensation for these 

executives from pre-TARP levels or 

believes that OSM’s existing processes are 

sufficient. The question is whether it is 

sufficient for taxpayers. Treasury continues 

to award excessive pay packages, including 

large guaranteed cash salaries. Meaningful 

reform is still possible because GM and Ally

remain under OSM’s jurisdiction. Without 

meaningful reform, including independent 

analysis by OSM, Treasury risks that TARP 

companies could potentially misuse taxpayer 

dollars for excessive executive 

compensation.

Second, while historically the Government 

has not been involved in pay decisions at 

private companies, one lesson of this 

financial crisis is that regulators should take 
Treasury Continues Approving Excessive Pay for Top Executives

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SIGTARP 13-001 January 28, 2013

an active role in monitoring and regulating 

factors that could contribute to another 

financial crisis, including executive 

compensation that encourages excessive risk 

taking. According to OSM, OSM’s 

authority to set pay for AIG executives has 

ended. SIGTARP previously reported that 

AIG CEO Benmosche told SIGTARP that 

the Special Master’s practices would have 

no lasting impact. He also said, however, 

that pay and performance must be linked, 

and if the majority of income is fixed, or 

guaranteed, then pay is not linked to 

performance. Given AIG’s considerable 

pushback on OSM’s limitations on pay as 

reported in SIGTARP’s prior report, it is 

highly likely that AIG could return to past 

compensation practices. The responsibility 

shifts to the Federal Reserve Board to ensure 

that AIG does not encourage excessive risk 

taking through compensation.

What SIGTARP Recommended

In this report, SIGTARP recommended that 

each year Treasury should reevaluate 

compensation for employees in the Top 25 

from the prior year; develop policies, 

procedures, and criteria for approving pay in 

excess of Treasury guidelines; 

independently analyze whether good cause 

exists to award a pay raise or cash salary 

over $500,000; and return to using longterm restricted stock for employees, 

particularly for senior employees such as 

CEOs.

Treasury provided an official written 

response to a draft of this report in a 

letter dated January 25, 2013, which is 

produced in full in Appendix H. Treasury

did not agree to implement any of the 

recommendations contained in the 

report. A fuller discussion of Treasury’s 

response can be found in the Management 

Comments section of the report.
Treasury Continues Approving Excessive Pay for Top Executives

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SIGTARP 13-001 January 28, 2013

Table of Contents

Introduction.................................................................................................................................... 1

Background ................................................................................................................................... 3

The Process Developed by Special Master Feinberg To Approve Pay Packages........ 4

SIGTARP Publishes Its Report on the Office of the Special Master’s Process ............. 5

Acting Special Master Sets 2012 Pay Packages with Input from Companies and 

Senior Treasury Officials......................................................................................................... 5

Treasury Approved Pay Packages Worth $3 Million or More for 54% of the 69 Top 25 

Employees, with 16 Pay Packages Worth at Least $5 Million.............................................. 7

In 2012, Treasury Approved Pay Packages Worth at Least $1 Million for Every 

Employee Except One Under the Special Master’s Pay-Setting Jurisdiction, and 

Approved All but One AIG Employee To Receive Pay Packages Worth at Least 

$2 Million.................................................................................................................................... 9

Treasury Failed To Take Sufficient Meaningful Action in Response to SIGTARP’s 

Prior Report............................................................................................................................... 9

Despite Creating Guidelines Aimed at Curbing Excessive Pay, Treasury Approved 

Approximately $37 Million in Executive Compensation for Top 25 Employees at AIG, 

GM, and Ally that Exceeded Its Own Guidelines .................................................................. 10

To Curb Excessive Compensation, Treasury Guidelines Provided that an Employee’s 

Total Compensation Generally Should Not Exceed the 50th Percentile for Similarly 

Situated Employees at Similarly Situated Companies. However, in 2012, Treasury Set 

Pay Greater than the 50th Percentile for 63% of Top 25 Employees at AIG, GM, and 

Ally ............................................................................................................................................ 12

Treasury Approved All 18 Pay Raises for Top 25 Employees at AIG, GM, and Ally 

Requested by the Companies, Including a $1 Million Raise for an AIG Senior Official

................................................................................................................................................... 13

In 2012, Treasury Allowed 70% of the Top 25 Employees at AIG, GM, and Ally To Be 

Paid Cash Salaries of $500,000 or More, with 33% Paid Cash Salaries of More than 

$500,000...................................................................................................................................... 16

Lacking Criteria and an Effective Decision-Making Process, Treasury Risks 

Continuing To Give Employees of Bailed-Out Companies Excessive Cash 

Compensation Without Good Cause .................................................................................. 17

Treasury Awarded Cash Salaries Exceeding $500,000 for Five Additional Employees, 

Four of Whom Exceeded the 50th Percentile.................................................................... 19

Treasury Did Not Use Incentive Compensation Tied to Performance Metrics for 

Approximately 50% of the Top 25 Employees .................................................................. 21
Treasury Continues Approving Excessive Pay for Top Executives

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SIGTARP 13-001 January 28, 2013

In 2012, AIG, GM, and Ally Failed To Take into Account Their Exceptional Situations 

that Resulted in Taxpayer Bailout........................................................................................ 25

Conclusions and Recommendations ...................................................................................... 28

Recommendations ..................................................................................................................... 36

Management Comments and SIGTARP’s Response .......................................................... 37

Appendix A – Objectives, Scope, and Methodology ............................................................ 38

Appendix B – AIG Determinations........................................................................................... 40

Appendix C – Ally Determinations........................................................................................... 41

Appendix D – GM Determinations........................................................................................... 42

Appendix E – Principles of TARP Standards for Compensation and Corporate 

Governance; Interim Final Rule ............................................................................................... 43

Appendix F – Acronyms and Abbreviations........................................................................... 45

Appendix G – Evaluation Team Members ............................................................................. 46

Appendix H – Management Comments.................................................................................. 47
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Introduction

In April 2012, with Americans throughout our country still feeling the effects 

of the financial crisis, the U.S. Department of the Treasury (“Treasury”)

approved multimillion-dollar pay packages for top executives at the three 

largest bailed-out companies remaining in the Troubled Asset Relief Program 

(“TARP”): American International Group, Inc. (“AIG”), General Motors 

Corporation (“GM”), and Ally Financial Inc. (“Ally,” formerly General 

Motors Acceptance Corporation, Inc.).

When Congress passed TARP and subsequent economic stimulus legislation, 

it placed strict limitations on executive compensation for TARP recipients. 

Treasury Secretary Timothy F. Geithner said that executive compensation 

played a material role in causing the financial crisis because it encouraged 

excessive risk taking. Congress left it to Treasury to implement limitations on 

executive compensation on TARP recipients. Treasury created TARP 

Standards for Compensation and Corporate Governance; Interim Final Rule

(“IFR,” or “Treasury’s Rule”). Treasury’s IFR created the Office of the

Special Master for TARP Executive Compensation (“OSM”) and set forth six 

principles under which OSM operates. Kenneth R. Feinberg, who served as 

the Special Master – often called the pay czar – until September 2010, called 

the principles inherently inconsistent. The Special Master’s primary mission 

is to set individual pay packages for the Top 251 employees at those 

companies whose amount and nature of their TARP bailout were considered 

“exceptional.” Feinberg was succeeded by Acting Special Master Patricia 

Geoghegan.

On January 23, 2012, the Office of the Special Inspector General for the 

Troubled Asset Relief Program (“SIGTARP”) published “The Special 

Master’s Determinations for Executive Compensation of Companies 

Receiving Exceptional Assistance Under TARP.” SIGTARP found that, from 

2009 to 2011, the Special Master could not effectively rein in excessive 

compensation at the seven companies that received exceptional assistance

under TARP because he was under the constraint that his most important goal 

was to get the companies to repay and exit TARP.

2 SIGTARP reported that 

 1 The Top 25 includes the 5 senior executive officers and the next 20 most highly compensated employees. 

Members of the Top 25 may vary from year to year. 2 The seven companies were American International Group, Inc. (“AIG”), Citigroup Inc. (“Citigroup”), Bank of 

America Corporation (“Bank of America”), Chrysler Holding LLC (“Chrysler”), General Motors Corporation 

(“GM”), Ally Financial Inc. (“Ally,” formerly General Motors Acceptance Corporation, Inc.), and Chrysler 

Financial Services Americas LLC (“Chrysler Financial”). 
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SIGTARP 13-001 January 28, 2013

under conflicting principles and pressures, despite reducing some pay, OSM 

approved pay packages worth $5 million or more for 49 individuals.

In addition, SIGTARP reported that OSM did not establish meaningful criteria

for granting exceptions to what Feinberg called “prescriptions” – that total 

compensation should target the 50th percentile for similarly situated 

employees at similarly situated entities, and that cash salaries should not 

exceed $500,000, except for good cause. SIGTARP reported that the 

companies proposed that their employees be paid cash salaries higher than 

$500,000, claiming that their employees were crucial, and that for 

10 employees in 2009, and 22 employees in both 2010 and 2011, GM, 

Chrysler Financial Services Americas LLC, Ally, and AIG convinced OSM to 

approve cash salaries greater than $500,000. SIGTARP recommended that 

OSM substantiate good cause to pay an employee more than $500,000 in cash. 

SIGTARP reported that it was unable to analyze whether OSM consistently 

applied the 50th percentile criteria because OSM did not maintain records of 

the market data showing how it determined the 50th percentile and 

recommended that OSM better document its use of market data. SIGTARP 

further recommended that OSM develop more robust policies, procedures, or 

guidelines for setting pay.

SIGTARP began a second evaluation, to assess OSM’s pay-setting process for 

2012 for Top 25 employees at AIG, GM, and Ally, in light of the serious and 

significant findings and recommendations in SIGTARP’s report.3

 

SIGTARP conducted this evaluation in accordance with the “Quality 

Standards for Inspection and Evaluation” established by the Council of the 

Inspectors General on Integrity and Efficiency. For a discussion of the 

evaluation’s scope and methodology, see Appendix A.

 3 In December 2012, Treasury sold its remaining AIG common stock.
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Background

In June 2009, Treasury issued an IFR, or Treasury’s Rule, which consolidated 

all TARP executive compensation restrictions into a single rule and created

OSM. OSM has jurisdiction over compensation at companies that stood out 

from the more than 700 TARP recipients because of the amount and nature of 

their “exceptional” bailouts. Originally, seven companies fell under OSM’s 

jurisdiction.4 In 2012, AIG, GM, and Ally were the three companies 

remaining subject to OSM’s review, until December 2012, when AIG repaid 

Treasury. OSM’s primary responsibility is to set pay for each of the Top 25 

employees at the TARP exceptional assistance recipients.5

Under Treasury’s Rule, the Special Master must determine whether 

compensation structures and payments are inconsistent with the law or are 

otherwise contrary to the public interest. Special Master Feinberg testified 

before the U.S. House of Representatives Committee on Financial Services 

that this public interest standard is satisfied when a compensation package 

appropriately balances two competing obligations: Pay packages should not 

be excessive, to “protect the public good,” but should be sufficient, to 

“maximize the public’s investment in the financial industry.” In meeting this 

standard, the Special Master must apply six principles and use discretion to 

determine the appropriate weight or relevance of those principles depending 

on the facts and circumstances or when principles conflict.

According to Feinberg, who served as Treasury’s Special Master from 

June 15, 2009, until September 10, 2010, the principles in Treasury’s Rule 

under which OSM operates are inherently inconsistent. Three OSM principles 

illustrate this inconsistency: The principle on “comparable structures and 

payments” states that compensation should be consistent with that of persons 

in similar positions or roles at similar entities, while principles on “appropriate 

allocation” and “risk” call for a significant portion of compensation to be paid 

over the long term and for compensation to avoid incentives to take excessive 

risks. Therefore, compensation paid over the long term may avoid excessive 

risk and may not reflect compensation of an employee’s peers, particularly in 

industries where compensation practices have historically encouraged 

excessive risk taking.

 4 As reported by SIGTARP in its January 23, 2012, report, OSM’s work had little effect on Citigroup and Bank of 

America, which quickly exited TARP, in part to avoid OSM’s restrictions. 5 OSM also approves compensation structures (rather than setting individual pay packages) for certain executive 

officers and the next 75 most highly compensated employees.
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SIGTARP 13-001 January 28, 2013

As SIGTARP previously reported, Feinberg told the Congressional Oversight 

Panel that the single most important thing he could do was to get the seven 

companies to repay the taxpayer. Feinberg said that TARP companies 

pressured him to let the companies pay executives enough to keep them from 

quitting, and that Treasury officials pressured him to let the companies pay 

executives enough to keep the companies competitive and on track to repay 

TARP.

The Process Developed by Special Master Feinberg To Approve

Pay Packages

Feinberg tried to shift compensation for Top 25 employees away from large 

guaranteed cash salaries and toward stock using what he called 

“prescriptions.” In trying to keep the companies competitive, Feinberg told 

SIGTARP that the 50th percentile was an “obvious” starting point and an 

“appropriate” level of compensation. According to Feinberg, his decision to 

limit cash salaries to $500,000 and to increase the proportion of compensation 

in the form of stock struck a balance between reducing excessive risk and 

providing enough compensation to keep employees’ “skin in the game.” 

Under Feinberg’s determination process, the companies submit market data

that indicate the market pay for each Top 25 employee. OSM uses Equilar’s 

ExecutiveInsight Total Compensation Report,

6 among other resources, to

assess the reasonableness of that market data. 

Attempting to keep employees’ “skin in the game” and rejecting guaranteed 

income, OSM apportioned total pay between cash salary, stock salary, and 

long-term restricted stock using a “prescription” that cash salaries should not 

exceed $500,000 per year, except for good cause. Under the process Feinberg 

developed, OSM determines cash salary by assessing the market data, the 

prior year’s compensation, the importance of the position and individual, the 

risk that an employee would leave, and any unique circumstances. OSM’s 

letters to the companies, which set the pay packages for Top 25 employees, 

state that cash salaries should target the median cash salaries for persons in 

similar positions or roles at similar entities and should generally not exceed 

$500,000. OSM determines how much of the remaining compensation would 

 6 Equilar’s ExecutiveInsight Total Compensation Report is an executive compensation benchmarking tool.
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SIGTARP 13-001 January 28, 2013

be paid in stock salary earned immediately versus long-term restricted stock.

OSM used this process for 2009, 2010, and 2011 pay.7 

In his final recommendation, Special Master Feinberg made recommendations 

to his successor. Feinberg recommended that his successor “limit guaranteed 

cash,” “demand a performance component for most compensation,” and “hold 

the line on cash salaries.”

SIGTARP Publishes Its Report on the Office of the Special 

Master’s Process

On January 23, 2012, SIGTARP published its report on executive 

compensation in which SIGTARP found that the Special Master failed to rein 

in excessive pay and pointed to significant issues with OSM’s process to set 

pay. SIGTARP’s report recommended that OSM (1) substantiate good cause 

for cash salaries greater than $500,000; (2) better document its use of market 

data to determine the 50th percentile; and (3) develop more robust policies, 

procedures, or guidelines to help ensure that the pay packages it approves are 

evenhanded. 

Treasury’s formal response to SIGTARP’s report came from Acting Special 

Master Geoghegan, who stated: “...OSM has succeeded in achieving its 

mission. Our office was effective at limiting compensation at the seven 

companies over which it had authority, while ensuring the companies were 

well-positioned to pay back the taxpayers’ investments.” The Acting Special 

Master also stated that OSM reduced pay for the companies’ Top 25 

executives.

Acting Special Master Sets 2012 Pay Packages with Input from 

Companies and Senior Treasury Officials

The companies submitted their pay package proposals in early February 2012, 

along with market data of compensation of persons in similar positions or 

roles at peer group entities selected by each company. Each company hired a 

compensation consultant to prepare its market data. Under Treasury’s Rule, 

OSM has 60 days to issue determinations on individual pay packages when 

 7 On October 22, 2009, OSM issued its first compensation determinations for 137 employees of 7 companies that 

had received TARP exceptional assistance. In December 2009, Bank of America and Citigroup repaid their 

exceptional assistance and were no longer subject to the Special Master’s rulings. On March 23, 2010, OSM 

issued 2010 pay determinations for 121 employees of the 5 remaining companies. In May 2010, Chrysler 

Financial exited TARP. On April 1, 2011, OSM issued compensation determinations for 98 employees of the 

remaining 4 companies. In July 2011, Chrysler exited TARP.
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SIGTARP 13-001 January 28, 2013

the company proposals are received by OSM and considered “substantially 

complete.” In late February or early March, company officials came to 

Washington, D.C., to meet with the Acting Special Master, who told 

SIGTARP that she wanted to hear what the companies thought was important. 

The Acting Special Master told SIGTARP that she also met at least twice each 

with each of four senior Treasury officials, including Deputy Secretary Neal 

S. Wolin and Assistant Secretary for Financial Stability Timothy Massad. 

The Acting Special Master told SIGTARP that she wanted to get Assistant 

Secretary Massad’s view on whether the companies were doing well or had 

any challenges and that they talked about specific employees’ pay. The

Acting Special Master told SIGTARP that, from a practical point of view, she 

reports to Assistant Secretary Massad. 

Prior to the Acting Special Master’s final decisions on the pay packages, she 

met with Deputy Secretary Wolin to brief him so that he would know what 

OSM was presenting in the determination memorandums. When asked about 

her meetings with Wolin, the Acting Special Master told SIGTARP that the

purposes of the meetings were to inform her decisions, but no one said she 

had to do anything differently.

On April 6, 2012, OSM issued pay determinations to the three remaining 

companies under OSM’s jurisdiction – AIG, GM, and Ally – setting pay for 

each Top 25 employee.

8 Just prior to that date, Treasury owned a 70% stake 

in AIG, a 32% stake in GM, and a 74% stake in Ally. Treasury set pay for 

69 employees of these companies (fewer than 25 employees per company 

because some employees had left their company during the year).

 8 AIG received $67.8 billion under the Systemically Significant Failing Institutions Program. Ally received 

$17.2 billion under the Automotive Industry Financing Program. GM received $49.5 billion under the 

Automotive Industry Financing Program, $400 million under the Auto Warranty Commitment Program, and 

$300 million under a program aimed at supporting auto suppliers. 
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SIGTARP 13-001 January 28, 2013

Treasury Approved Pay Packages Worth 

$3 Million or More for 54% of the 69 Top 25 

Employees, with 16 Pay Packages Worth at

Least $5 Million

Treasury approved pay packages worth $5 million or more for 23% of the 

Top 25 employees at AIG, GM, and Ally.

9

 This equaled 16 out of 69 

employees (9 AIG employees, 3 GM employees, and 4 Ally employees). In 

addition, Treasury approved pay ranging from $3 million to $4.9 million for

21 out of the 69 employees (12 AIG employees, 4 GM employees, and 5 Ally 

employees). 

 9 SIGTARP previously reported that, from 2009 to 2011, Treasury approved pay packages worth $5 million or more 

for 49 Top 25 employees of the 7 companies that had received exceptional TARP assistance.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 8

SIGTARP 13-001 January 28, 2013

Table 1 below shows Treasury-approved pay packages of $5 million or more.

TABLE 1

2012 OSM-APPROVED COMPENSATION PACKAGES VALUED AT $5 MILLION OR HIGHER

Employees 

Identified

Company 

Name Title Cash Salary

($)

Stock 

Salary

 ($)

Long-Term 

Restricted 

Stock ($)

Total Direct 

Compensation

($)

1 AIG CEO 3,000,000 7,500,000 0 10,500,000

2 Ally CEO 0 9,500,000 0 9,500,000

3 GM Chairman and CEO 1,700,000 7,300,000 0 9,000,000

4 Ally CEO Mortgage and CM 600,000 7,403,449 0 8,003,449

5 AIG CEO Chartis 1,800,000 5,200,000 1,000,000 8,000,000

6 AIG President and CEO SAFG 495,000 5,315,000 1,190,000 7,000,000

7 AIG EVP, Chief Financial Officer 495,000 4,734,000 1,071,000 6,300,000

8 AIG EVP, Investments and 

Financial Services 450,000 5,550,000 0 6,000,000

9 AIG [1] 500,000 5,500,000 0 6,000,000

10 Ally [1] 600,000 5,024,828 0 5,624,828

11 AIG [1] 495,000 4,070,234 934,766 5,500,000

12 AIG [1] 975,000 4,425,000 0 5,400,000

13 GM Vice Chairman [2] 600,000 3,300,000 1,500,000 5,400,000

14 Ally Chief Administrative Officer 600,000 4,587,357 0 5,187,357

15 GM Senior Vice President and 

Chief Financial Officer 750,000 2,600,000 1,650,000 5,000,000

16 AIG [1] 700,000 3,050,000 1,250,000 5,000,000

Totals $13,760,000 $85,059,868 $8,595,766 $107,415,634

Source: SIGTARP analysis of OSM’s determination memorandums.

[1] Information not publicly available.

[2] Corporate Strategy, Business Development, Global Product Planning and Global Purchasing and Supply Chain.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 9

SIGTARP 13-001 January 28, 2013

In 2012, Treasury Approved Pay Packages Worth at Least 

$1 Million for Every Employee Except One Under the Special 

Master’s Pay-Setting Jurisdiction, and Approved All but One AIG 

Employee To Receive Pay Packages Worth at Least $2 Million

Treasury seemingly set a floor, awarding 2012 total pay of at least 

$1 million.10 Treasury also approved pay ranging from $2 million to 

$2.9 million for 19 employees (4 GM employees, 12 Ally employees, and 

3 AIG employees). Treasury approved pay ranging from $1.2 million to 

$1.9 million for 12 GM employees. Moreover, Treasury approved 24 of 

AIG’s Top 25 employees to receive pay packages worth at least $2 million.

Treasury Failed To Take Sufficient Meaningful Action in 

Response to SIGTARP’s Prior Report

Despite SIGTARP’s January 2012 report identifying serious concerns with 

OSM’s pay-setting process, Treasury continued to use the same process for 

setting 2012 pay without significant change. According to Acting Special 

Master Geoghegan, the process OSM used to set 2012 pay packages has not 

changed. She told SIGTARP that this was OSM’s fourth year and the 

companies were not proposing anything out of the ordinary. 

Even though SIGTARP recommended that OSM develop more robust 

policies, procedures, or guidelines, to date, OSM has not done so. Moreover, 

despite SIGTARP finding that OSM had no criteria for determining good 

cause for an employee to be paid a cash salary exceeding $500,000, OSM still 

lacks such criteria. In 2012, OSM did not independently analyze the basis for 

awarding cash salaries greater than $500,000. The only changes that OSM 

has made to its process in response to SIGTARP’s recommendations relate to

documentation. OSM has begun to document explanations for cash salaries 

exceeding $500,000 on an eight-page spreadsheet and document market data 

it used for validating market estimates provided by each company.

11 

However, SIGTARP recommended that OSM substantiate, not just document, 

good cause for cash salaries greater than $500,000.

 10 Only one employee received Treasury-approved pay under $1 million. Treasury awarded this AIG employee a 

guaranteed cash salary of $700,000. 11 OSM documented its procedures to evaluate the reasonableness of company-supplied market rates. OSM 

documented how it reviewed company-supplied market data, its method for sampling jobs from the Top 25 

positions that it would test, its selection of market comparator peer groups, and its matching of rates at both the 

median and the 75th percentile. OSM included in its pay decisions an overview about the market data supplied by 

each company. The overviews disclose which compensation firms were employed by AIG, Ally, and GM, and the 

market data the firms used. The overviews also summarize the methods the firms employed to determine market 

compensation rates.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 10

SIGTARP 13-001 January 28, 2013

Despite Creating Guidelines Aimed at Curbing 

Excessive Pay, Treasury Approved 

Approximately $37 Million in Executive 

Compensation for Top 25 Employees at AIG, 

GM, and Ally that Exceeded Its Own 

Guidelines

In SIGTARP’s last report, SIGTARP found that then-Special Master Feinberg 

could not effectively rein in excessive compensation because he was under the 

constraint that his most important goal was to get the companies to repay and 

exit TARP. This appears to be the case for Acting Special Master Geoghegan 

as well, who told SIGTARP that the companies should be competitive in their 

industry so they can pay back the taxpayer.

For example, OSM’s written “justification” for AIG CEO Robert 

Benmosche’s $3 million cash salary reads, “under executive’s leadership, 

company has repaid 75% of total government assistance.” However, the 

justification is questionable because OSM has approved Benmosche’s 

$3 million cash salary under his $10.5 million total pay package for four 

consecutive years.

Despite Special Master Feinberg’s “prescriptions” aimed at curbing excessive 

pay by shifting pay away from large cash salaries and toward stock, Acting 

Special Master Geoghegan, who set pay in 2011 and 2012, considered one of 

his prescriptions (limiting cash salaries to $500,000) to be a discretionary

guideline and made a significant number of exceptions to it. Without 

appropriate criteria to implement the guidelines, in 2012, the Acting Special 

Master approved compensation that was largely driven by the three 

companies’ proposals. For example:

 The Acting Special Master approved pay packages exceeding the 50th

percentile by approximately $37 million for 43 of 68 employees (63%)

proposed by the 3 companies. 

 OSM approved all 18 pay raises requested by the companies.

 OSM approved cash salaries above $500,000 for 23 of 26 employees,

proposed by the companies, the highest number of employees under 
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 11

SIGTARP 13-001 January 28, 2013

OSM’s pay-setting jurisdiction to receive cash over $500,000 compared to 

any other year. The companies proposed that 41 out of 68 (approximately 

60%) of the Top 25 employees be paid cash salaries over the market

median, and OSM approved this for 38 (approximately 56%) of the 

employees. 

 Despite one key principle set forth in Treasury’s Rule calling for 

performance-based pay, upon the companies’ requests, OSM did not use

long-term incentive stock tied to meeting performance criteria for half of 

the executives (9 AIG, 4 GM, and all of Ally’s 21 Top 25 employees for a 

total of 34 employees). Moreover, Acting Special Master Geoghegan 

removed long-term restricted stock from 24 of the 34 employees’ pay 

packages, and for all but 1 of the 24 employees, replaced it with stock 

salary, as requested by the companies.

As illustrated in Table 2 below, OSM approved 43 pay packages 

(approximately $37 million) and 38 cash salaries (approximately $6 million) 

exceeding market medians. OSM also approved 23 cash salaries 

(approximately $8.5 million) exceeding $500,000. 

TABLE 2

2012 OSM-APPROVED PAY FOR 69 TOP 25 EMPLOYEES

OSM Guideline 

 Within

Guideline

Exceeded 

Guideline

% Exceeding

Guideline

Total Pay

Exceeding 

Guideline

Guideline 1:

Total Pay Should 

Target Market 

Median [1]

25 43 63% $37,426,547

Guideline 2:

Cash Salary 

Should Target 

Market Median[1]

30 38 56% $6,026,800

Guideline 3:

Cash Salary 

Should Not 

Exceed $500,000

46 23 33% $8,476,000

Source: SIGTARP analysis of OSM’s 2012 determination memorandums.

[1] For 1 of the 69 employees, OSM did not receive market data from the employee’s company. 

Therefore, there were 68 employees in SIGTARP’s sample.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 12

SIGTARP 13-001 January 28, 2013

To Curb Excessive Compensation, Treasury Guidelines Provided 

that an Employee’s Total Compensation Generally Should Not 

Exceed the 50th Percentile for Similarly Situated Employees at 

Similarly Situated Companies. However, in 2012, Treasury Set 

Pay Greater than the 50th Percentile for 63% of Top 25

Employees at AIG, GM, and Ally

In 2012, OSM did not follow its own guidelines aimed at curbing excessive 

pay by having total compensation generally not exceed the 50th percentile for 

similarly situated employees. According to OSM, the 50th percentile was 

“appropriate” and “reasonable” and allowed employees to be paid similarly to 

those in other financially distressed companies, while keeping the companies 

competitive. 

SIGTARP previously reported that companies pushed back on OSM by 

claiming that their compensation should be higher than the 50th percentile. In 

2012, companies continued to push for pay packages exceeding the 50th 

percentile. The 3 companies (AIG, GM, and Ally) proposed that 43 of 68 of 

their Top 25 employees (approximately 63%) receive total pay packages 

exceeding the 50th percentile, and that was what Treasury approved. 

Acting Special Master Geoghegan told SIGTARP that, as a group, total pay 

for Ally’s employees was between the 50th and 75th percentiles. Geoghegan 

also stated that Ally hired the vast majority of its employees within the past 

three to four years. She reasoned that these individuals should receive pay 

between the 50th and 75th percentiles so that Ally could attract employees for 

short-term positions. However, SIGTARP is unaware of an OSM prescription 

or guideline calling for total pay to exceed the 50th percentile to attract 

employees for short-term positions.

Moreover, OSM approved pay packages exceeding the 50th percentile by 

approximately $1.7 million, $1.2 million, and $850,000 for three employees 

of Ally’s mortgage subsidiary, Residential Capital, LLC (“ResCap”),

including the CEO of ResCap, despite knowing that ResCap was planning to 

file for bankruptcy (which it did, weeks after OSM set pay packages).

12

 12 On May 14, 2012, Ally announced that its mortgage subsidiary, Residential Capital, LLC, filed for bankruptcy 

relief under Chapter 11 of the U.S. Bankruptcy Code. 
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 13

SIGTARP 13-001 January 28, 2013

Treasury Approved All 18 Pay Raises for Top 25 Employees at 

AIG, GM, and Ally Requested by the Companies, Including a 

$1 Million Raise for an AIG Senior Official

OSM approved all 18 of the raises proposed by the companies in 2012. These 

pay raises ranged from $30,000 to $1 million (1% to 23%), over the 

employees’ 2011 OSM-approved total pay. GM and Ally each proposed nine

pay raises, and AIG proposed one pay raise – a raise worth $1 million. 

The Acting Special Master approved the $1 million raise for Peter Hancock, 

CEO of AIG’s Chartis subsidiary,

13 which the Acting Special Master called “a 

significant raise” for one of the most important people at AIG after discussing 

it with senior Treasury officials including the Deputy Secretary.

14 OSM

approved an increase in cash salary from $500,000 to $550,000 for a ResCap 

employee, knowing that ResCap was planning for bankruptcy, with OSM 

noting that the executive was “critical to successful restructuring.”15 OSM

approved a $100,000 raise for an executive at GM’s European unit, knowing 

that unit was experiencing significant financial losses that dragged down the 

company’s earnings, with OSM noting, “losses in Europe are a significant 

challenge.” 

 13 Peter Hancock was named chief executive officer of Chartis, AIG’s global property casualty business, in 

March 2011, when Chartis was reorganized into two major global groups, commercial and consumer. 14 The Acting Special Master told SIGTARP that AIG decreased proposed pay raises for other employees. 15 GM Europe reported earnings before interest and taxes adjusted loss of $400 million in the second quarter of 

2012. GM Chairman and CEO Dan Akerson said that, despite solid results in some areas, the company has to 

offset the headwinds it faces in Europe and South America.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 14

SIGTARP 13-001 January 28, 2013

Table 3 below illustrates 2012 OSM-approved pay raises for the 18 

employees.

TABLE 3

2012 OSM-APPROVED PAY INCREASES (SORTED BY PAY INCREASE, IN DOLLARS)

Employees 

Identified

Company 

Name Title

2011 Total 

Pay Package

($)

2012 Total 

 ($)

Pay Increase

($)

Pay Increase

(%)

1 AIG CEO Chartis $7,000,000 $8,000,000 $1,000,000 14%

2 GM [1] 3,500,000 4,300,000 800,000 23

3 GM Senior Vice President and 

Chief Financial Officer 4,200,000 5,000,000 800,000 19

4 GM [1] 3,500,000 4,250,000 750,000 21

5 GM [1] 4,200,000 4,850,000 650,000 15

6 GM [1] 2,550,000 2,925,000 375,000 15

7 Ally President GAS 3,647,280 3,991,000 343,720 9

8 GM [1] 1,900,000 2,150,000 250,000 13

9 Ally President Mortgage 

Operations 3,000,000 3,200,000 200,000 7

10 Ally EVP NA Operations 2,603,414 2,800,000 196,586 8

11 Ally [1] 2,606,436 2,800,000 193,564 7

12 Ally [1] 2,414,252 2,600,000 185,748 8

13 Ally Chief Financial Officer 2,855,738 3,000,000 144,262 5

14 GM Vice Chairman [2] 5,300,000 5,400,000 100,000 2

15 Ally SEVP, Finance and 

Corporate Development 4,343,678 4,397,892 54,214 1

16 GM [1] 2,050,000 2,100,000 50,000 2

17 Ally [1] 3,603,830 3,642,944 39,114 1

18 GM [1] 1,900,000 1,930,000 30,000 2

Totals $61,174,628 $67,336,836 $6,162,208

Source: SIGTARP analysis of OSM’s determination memorandums.

[1] Information not publicly available.

[2] Corporate Strategy, Business Development, Global Product Planning and Global Purchasing and Supply Chain.

OSM’s written explanations for the pay raises lack substance, some of which 

parroted what each company asserted to OSM. For example, OSM approved 

one pay raise on the basis that “company reports executive is successfully 

leading the transformation of the company’s largest subsidiary,” which is 

essentially what the company stated in its proposal. Other OSM explanations 
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 15

SIGTARP 13-001 January 28, 2013

stated that employees were “retention risks” (people at risk of leaving), were 

crucial, or were strong performers, but provided no analysis to justify the 

raise. OSM approved raises of 15% to 23% without any further detail or 

analysis for four employees on the basis that they were among the individuals 

that GM’s CEO most relied on, and they had received significant promotions 

or increased job responsibilities. 

OSM officials told SIGTARP that OSM follows up when it doubts a 

company’s assertion and they were not suspicious of any assertion by the 

company. OSM officials told SIGTARP that they approved the pay raises 

after assessing information provided by each company, speaking with 

company officials, and reviewing publicly available information and 

employee market data. In addition, the company’s statements get a general 

check from Assistant Secretary Massad and Treasury’s Chief Investment 

Officer. For example, if a company claims that an employee took on 

additional responsibilities, OSM may ask for additional information, but does 

not challenge the company. 
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 16

SIGTARP 13-001 January 28, 2013

In 2012, Treasury Allowed 70% of the Top 25 

Employees at AIG, GM, and Ally To Be Paid 

Cash Salaries of $500,000 or More, with 33% 

Paid Cash Salaries of More than $500,000

Treasury aimed to curb excessive pay by setting a guideline that cash salaries 

generally should not exceed $500,000. The President announced a $500,000 

salary cap for top executives at TARP companies that had received 

exceptional assistance, with any further compensation to be paid in stock that 

could not be cashed out until TARP was repaid. OSM staff told SIGTARP 

that the $500,000 cash salary cap was based partially on the President’s 

statement. As discussed earlier in this report, Special Master Feinberg told 

SIGTARP that he decided to limit cash salaries to $500,000, and to increase 

the proportion of compensation in the form of stock to strike a balance 

between reducing excessive risk and providing enough compensation to keep 

employees’ “skin in the game.” Feinberg, in testimony before the U.S. House 

of Representatives Committee on Financial Services, stated, “...base cash 

salaries should rarely exceed $500,000, and only then for good cause shown, 

and should be, in many cases, well under $500,000.”

Despite Acting Special Master Geoghegan’s public memorandums to the 

companies that state that, other than exceptional cases for good cause shown, 

cash salary should not exceed $500,000, the Acting Special Master told 

SIGTARP there is no cash salary cap. She also said that Feinberg’s governing 

“prescription” of $500,000 is a “discretionary guideline” and OSM has always 

allowed exceptions. She described the $500,000 guideline as useful but told 

SIGTARP that there is no law or regulation that says that she needs a memo to 

permit a company to go above $500,000. 

Never have there been so many exceptions to the $500,000 cash salary 

guideline for the amount of people under the Acting Special Master’s 

jurisdiction as there were in 2012. Despite the fact that the number of 

companies under OSM’s jurisdiction decreased from 4 in 2011 to 3 in 2012, 

the Acting Special Master increased the number of employees with cash 

salaries greater than $500,000 from 22 to 23 in those years, respectively. This 

increase has significance. OSM approved 2012 cash salaries exceeding 

$500,000 for one-third of the employees within OSM’s pay-setting 

jurisdiction (23 of 69 Top 25 employees at AIG, GM, and Ally). In 2012, the

companies had requested that 26 employees be paid cash salaries exceeding 

$500,000.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 17

SIGTARP 13-001 January 28, 2013

As illustrated in Figure 1 below, the number of employees earning Treasuryapproved cash salaries greater than $500,000 has nearly quadrupled – from 6 

in 2009 to 23 in 2012 – despite the fact that the number of companies 

receiving exceptional assistance under TARP continues to decrease as the 

companies repay and exit TARP.

FIGURE 1

2009-2012 OSM-APPROVED CASH SALARIES EXCEEDING $500,000

Source: SIGTARP analysis of OSM’s determination memorandums.

In addition to questioning the approval of cash salaries greater than $500,000 

for one-third of the employees, SIGTARP questions whether OSM is 

following the spirit of its $500,000 cash salary guideline. Notably, in addition 

to approving 23 employees to receive cash salaries of more than $500,000, 

OSM allowed 25 employees to have cash salaries exactly at the $500,000 

guideline. Accordingly, OSM allowed cash salaries of $500,000 or more for 

70% (48 of 69) of Top 25 employees at AIG, GM, and Ally. OSM allowed 

cash salaries of $450,000 or more for 94% (65 of 69) of Top 25 employees at 

AIG, GM, and Ally.

Lacking Criteria and an Effective Decision-Making Process, 

Treasury Risks Continuing To Give Employees of Bailed-Out 

Companies Excessive Cash Compensation Without Good Cause 

Despite SIGTARP warning in its January 2012 report on executive 

compensation that OSM did not establish meaningful criteria for good cause 

6

14

22

23

1

5 5

6

2

9

11

10

3

0

6

7

0

5

10

15

20

25

2009 2010 2011 2012

All 3 Companies

AIG

GM

Ally

Number of 

Employee Pay Packages
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 18

SIGTARP 13-001 January 28, 2013

for a cash salary of more than $500,000 and that OSM approved cash salaries 

greater than $500,000 with limited justifications, Treasury did not establish 

criteria in response to SIGTARP’s report. After SIGTARP’s report, when 

SIGTARP asked the Acting Special Master what criteria OSM used to 

determine good cause for cash salaries exceeding $500,000, she told 

SIGTARP that Treasury’s Interim Final Rule is OSM’s criteria. However, the 

IFR does not contain criteria for limiting cash salaries. Unless OSM 

establishes and follows meaningful criteria to determine good cause to pay an 

employee more than $500,000 in cash, OSM risks continuing to give

employees of bailed-out companies excessive cash compensation without 

good cause and cloaking its decisions in vague generalities. 

Similar to OSM’s explanations for approving pay raises, OSM’s 

“justifications” for excessive cash salaries parrot what each company asserted 

to OSM. Some of the companies’ justifications of good cause for a $500,000

cash salary were in oral statements to OSM officials. 

By using only Treasury’s 60-day process to set pay packages for Top 25 

employees, OSM missed an opportunity to limit the employee cash salaries to 

$500,000. Acting Special Master Geoghegan told SIGTARP that OSM does 

not perform an independent analysis, instead choosing to use data and 

assertions supplied by the companies. For example, if a company claims that 

an employee should be paid cash salary of more than $500,000 because of 

added duties, OSM does not look to see what duties the employee previously 

had in comparison. Acting Special Master Geoghegan explained to SIGTARP 

that, if OSM worked along those lines, it would take a year to conduct the 

determinations, but OSM asks for the information in January and cannot ask 

for the information before then because OSM needs the companies to finish 

the year. Acting Special Master Geoghegan said OSM does not spend that 

much time on a “small decision” like whether to continue to give an 

individual $600,000.

The Acting Special Master’s explanation raises concerns as to why OSM does 

not perform substantive analysis related to the Top 25 employees earlier in the 

year, particularly because most of the Top 25 employees stayed the same from 

2011. Instead, OSM officials have chosen to conduct all of their work for 

their primary mission of setting Top 25 pay within the 60-day process. OSM 

could have been identifying specific Top 25 employees’ duties and value to 

the company throughout the year, and then use the end of the year information 

in the company’s proposals to supplement their existing information.

More importantly, the Acting Special Master appears to have no desire to dig 

into a company’s justification of good cause for cash salaries greater than 
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 19

SIGTARP 13-001 January 28, 2013

$500,000. For example, in 2012, OSM approved cash salaries exceeding 

$500,000 for 19 of 23 employees with the explanation that the same number 

had been approved the previous year. The Acting Special Master told 

SIGTARP that it would be normal for these individuals in the Top 25 to 

expect more than $500,000 in cash salary, and said there was no doubt that 

these people are making a large amount of money. The Acting Special Master 

told SIGTARP, “OSM would not normally reopen from scratch a 

determination that it made when you have executive compensation 

determinations from year to year” because it would be “incredibly disruptive,”

and it was relatively easy for OSM to keep things the way they were. She 

described taking an extra two hours to look at a person’s justification of added 

responsibility as a waste of time. She said that she did not think that when the 

$500,000 guideline was formulated, it would take an “independent little 

project” to determine when someone should go above $500,000. The Acting 

Special Master told SIGTARP that OSM is not the compensation committee. 

The Acting Special Master told SIGTARP that a lot of pay determinations 

were based on prior years pay, and absent a change in circumstances, OSM 

would not change pay. However, in 2012, Treasury approved cash salaries 

greater than $500,000 for GM’s troubled European unit, even though that unit

experienced significant financial losses and dragged down the company’s 

earnings.16 OSM approved one employee’s salary at $600,000, the same as in 

2011, but awarded him an increase in stock salary of $100,000 while noting 

that “losses in Europe are a significant challenge.” OSM also approved a cash 

salary of $600,000, the same as in 2011, for one ResCap employee, and a cash 

raise from $500,000 to $550,000 for another ResCap employee.

Treasury Awarded Cash Salaries Exceeding $500,000 for Five 

Additional Employees, Four of Whom Exceeded the 

50th Percentile

In 2012, Treasury approved cash salaries exceeding $500,000 for five 

additional employees. Because SIGTARP, in its prior evaluation, had already 

assessed OSM’s decisions to approve salaries in excess of $500,000 for 

18 employees of the 23 paid $500,000+ in cash, SIGTARP evaluated the five 

additional employees:

 16 Stephen J. Girsky, Vice Chairman, Corporate Strategy, Business Development, Global Product Planning and

Global Purchasing and Supply Chain. In 2011, OSM approved an $800,000 cash salary for David N. Reilly, GM 

Vice President and President, GM Europe. However, he retired on April 1, 2012, and did not receive an OSM 

2012 determination.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 20

SIGTARP 13-001 January 28, 2013

 SIGTARP found that four of the five employees who received cash 

salaries greater than $500,000 exceeded OSM’s guideline to target cash 

salaries at the 50th percentile by an aggregate $654,000.

 OSM approved a salary for a GM employee of $950,000, which on its face 

was excessive, when compared to OSM’s $500,000 cash salary guideline. 

The salary was $316,000 higher than the median cash salary of the 

employee’s peers. The employee came to GM in 2010 as part of an 

acquisition. The employee’s employment contract stipulated that his 

compensation, upon transitioning to GM, is subject to the Special Master’s 

restrictions. However, instead of limiting the employee’s salary to 

$500,000, or to the 50th percentile ($634,000), OSM approved the 

employee’s cash salary, set by the subsidiary before GM acquired it. 

OSM did not justify why an individual’s pay at an acquired subsidiary is 

relevant or why the pay could not be modified in 2012, given that the 

position was covered under the restrictions of the Acting Special Master. 

 OSM approved a salary for a GM employee of $580,000, which exceeded 

the 50th percentile by $160,000. OSM told SIGTARP that the employee 

was considered by GM to be a retention risk and was considered crucial in 

managing GM’s supply chain. OSM provided no further analysis.

 OSM’s written justification documenting its rationale states that there was 

good cause for a $650,000 cash salary for an AIG employee, in part 

because of a counteroffer agreement between AIG and the employee in 

December 2008, when the employee was reportedly offered a job with an 

AIG competitor. However, OSM did not explain why a purported 

agreement at AIG from 2008 would justify a 2012 cash salary that

exceeded the median cash salary of the employee’s peers by $135,000. 

 OSM approved a cash salary for an Ally employee of $550,000, which 

exceeded the 50th percentile by $43,000. OSM’s justification stated that 

Ally considered the employee to be critical. However, OSM did not 

provide an analysis or show it performed due diligence to substantiate 

Ally’s assertion.

In addition, for one employee who received a cash salary of $600,000 in 2011, 

OSM approved an additional $50,000 in cash in 2012. When asked why the 

employee received the raise, the Acting Special Master told SIGTARP that 

GM wanted to retain the employee and “do a little extra for him.”
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 21

SIGTARP 13-001 January 28, 2013

Treasury Did Not Use Incentive Compensation Tied to 

Performance Metrics for Approximately 50% of the Top 25 

Employees 

Acting Special Master Geoghegan did not use incentive compensation (longterm restricted stock) contingent on meeting performance standards for half of 

the executives, as requested by the companies.

By removing long-term restricted stock, Acting Special Master Geoghegan 

removed the tie of individual compensation to long-term company success for 

several employees. This is different from how OSM, under former Special 

Master Feinberg used long-term restricted stock contingent on the employee 

receiving specific performance criteria in order to tie individual compensation 

to long-term company success. 

Treasury’s Rule, under which OSM operates, provides that an appropriate 

portion of the compensation should be performance based over a relevant 

performance period, determined through tailored metrics that encompass 

individual performance and/or the performance of the TARP recipient or a 

relevant business unit, taking into consideration specific business objectives.17

Special Master Feinberg testified before the U.S. House of Representatives 

Committee on Financial Services, “Compensation of key officials at these 

companies that owe so much to the American taxpayer should depend on 

performance...What you earn, other than your base cash salary, should 

depend on long-term performance, objective metrics...” Feinberg testified 

before the House Committee on Oversight and Government Reform that OSM 

offered up the notion of long-term, incentive-based stock that cannot be sold 

until and unless the taxpayers get their money back, stating, “That’s the 

formula we tried to use to correct what we thought in our report were the 

problems with executive compensation practices in these seven companies.”

Despite Treasury’s Rule calling for appropriate allocations of pay to be 

performance based, and as illustrated in Table 4 below, 34 Top 25 employees 

did not receive long-term restricted stock in 2012 (9 AIG employees, 4 GM 

employees, and all 21 of Ally’s Top 25 employees). After making her 

decisions on pay in April 2012, she subsequently removed long term 

restricted stock for all of Ally’s Top 25 employees on the basis that the 

 17 Long-term restricted stock may be granted only if the employee meets performance criteria and generally only if 

an employee continues to provide services to the company for three years following the date of grant. The awards 

are redeemable only in 25% installments for each 25% of TARP obligations that are repaid. Unlike long-term 

restricted stock, stock salary immediately vests upon grant, and may be redeemed in three equal annual installments. 
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 22

SIGTARP 13-001 January 28, 2013

company’s subsidiary ResCap, had filed bankruptcy, and that the company 

had announced it was exploring strategic alternatives such as a possible sale of 

international operations. However, only three employees in Ally’s Top 25 

worked at ResCap and OSM knew in April that ResCap was planning a 

restructuring. In addition, both GM and AIG were selling international 

operations.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 23

SIGTARP 13-001 January 28, 2013

TABLE 4

EMPLOYEES WHO RECEIVED NO LONG-TERM RESTRICTED STOCK 

UNDER THE 2012 DETERMINATIONS

Company 

Name

Employee

ID #

2011 

Long-Term 

Restricted 

Stock

2012

Long-Term 

Restricted 

Stock

AIG 1 $0 $0

AIG 133 0 0

AIG 206 2,000,000 0

AIG 208 [1] 0

AIG 261 0 0

AIG 265 0 0

AIG 1076 0 0

AIG 1087 1,200,000 0

AIG 1105 [1] 0

GM 4859 2,000,000 0

GM 2986 1,165,000 0

GM 3348 250,000 0

GM 4894 0 0

Ally 280677 1,500,000 0

Ally 102645 1,729,119 0

Ally 104428 986,989 0

Ally 105336 750,000 0

Ally 141296 801,826 0

Ally 197253 1,162,163 0

Ally 265967 1,393,678 0

Ally 272446 666,000 0

Ally 339212 2,667,816 0

Ally 354392 724,943 0

Ally 391076 780,919 0

Ally 468046 [1] 0

Ally 513416 [1] 0

Ally 546145 1,215,760 0

Ally 567303 803,414 0

Ally 682168 1,841,495 0

Ally 707713 951,913 0

Ally 725547 868,812 0

Ally 805106 1,300,000 0

Ally 931656 836,958 0

Ally 960277 1,000,000 0

Source: SIGTARP analysis of OSM’s determination memorandums.

[1] These employees were not among the Top 25 in 2011.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 24

SIGTARP 13-001 January 28, 2013

Acting Special Master Geoghegan told SIGTARP that there are no criteria for 

taking away long-term restricted stock. When asked about individuals who 

did not receive long-term restricted stock in 2012, the Acting Special Master 

explained to SIGTARP that in general, when OSM takes away long term 

restricted stock, it is because the individual may be very senior, may wish to 

retire, or will be leaving. Referring to one employee, the Acting Special 

Master told SIGTARP that long-term restricted stock would be of no value 

unless the employee would stay at the company. She explained that the 

companies would tell OSM if they thought long-term restricted stock was 

inappropriate for an employee and that OSM’s decision usually starts with the 

company’s request. The Acting Special Master told SIGTARP that these were 

employees who had large amounts of long-term restricted stock, but none in 

2012 because the firms do not expect these employees to remain at the 

company for the next two years and the employee cannot cash in the stock for 

two years. 

The Acting Special Master told SIGTARP that senior employees who are 

retiring do not benefit from long-term restricted stock and it is a burden to 

compensate them with long-term restricted stock. She explained, when 

talking about someone very senior, such as a company executive, it is not wise 

to give them large chunks of compensation that has no value. However, as 

stated earlier, Treasury’s Rule, under which OSM operates, provides that the 

appropriate allocation and the appropriate performance metrics may be 

different for different positions and for different employees, but generally a 

significant portion of total compensation should be performance-based 

compensation, and generally that portion should be greater for those in 

positions exercising higher levels of responsibility.
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SIGTARP 13-001 January 28, 2013

In 2012, AIG, GM, and Ally Failed To Take into Account Their 

Exceptional Situations that Resulted in Taxpayer Bailout

SIGTARP previously reported that in proposing high pay packages based on 

historical pay prior to their bailouts, the TARP companies failed to take into 

account the exceptional situations they had gotten themselves into that 

necessitated the need for financial rescues. In evaluating OSM’s 2012 

determinations, SIGTARP found that firms again failed to appreciate the 

extraordinary assistance provided by U.S. taxpayers.

Companies continue citing employee retention to justify excessive pay. 

SIGTARP’s prior report said that, given OSM’s overriding goal of getting 

TARP companies to repay the Government, the seven companies had leverage 

over OSM by proposing and negotiating for excessive pay packages. The 

report also said that the companies warned then-Special Master Feinberg that 

if he did not provide competitive pay packages, top executives would leave 

the companies. Feinberg found the claims dubious, and even reported that 

despite such claims, 85% of the executives who threatened to leave in 2009 

remained at their companies in 2010. In 2012, the companies also used 

retention as a justification for high pay. For 10 employees, the companies

asked OSM to approve cash salaries, ranging from $610,000 to $1.4 million, 

in part to keep the executives from departing the companies. 

AIG:

SIGTARP previously reported that AIG pushed for excessive raises in cash 

salaries and pushed against pay in AIG stock. SIGTARP’s report laid out how 

AIG CEO Benmosche felt that OSM penalized AIG with very low salaries. 

SIGTARP also reported that AIG proposed not to receive any incentive 

awards in long-term restricted stock tied to achievement of performance 

measures and that Benmosche enlisted the help of other Treasury officials,

asking them to talk to Feinberg.

AIG’s failure to take into account the exceptional situation it was in is echoed 

by comments by AIG CEO Benmosche to New York Magazine in 2012:

...it wasn’t a free lunch...we now have succeeded in getting the Fed 

back all of their money, and we’re close to getting the Treasury paid 

back. And do you know...neither of them have ever said Thank you? 

We have done all the right things. Somebody should say, by golly, 

those AIG people made a promise and they are living up to a promise! 

We’re left with a major part of the economy in America; they’re going 

to make a profit on top of everything else they’ve got...God bless 

America. And God bless AIG. And God bless Tiny Tim.
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SIGTARP 13-001 January 28, 2013

In 2011 and 2012, AIG’s pay proposals reflect the company’s request for 

excessive compensation. AIG’s CEO continued to receive the single largest 

Treasury-approved pay package of any employee – $10.5 million. In 2011, 

the Acting Special Master removed Benmosche’s incentive stock tied to 

meeting performance criteria, shifting it to stock salary that immediately vests. 

In 2012, she removed long-term restricted stock for two other AIG Top 25 

employees. Moreover, six other AIG Top 25 employees’ pay packages did 

not contain long-term restricted stock. Nine of the 16 Treasury-approved pay 

packages of $5 million or more were for AIG employees. Treasury approved 

pay from $3 million to less than $5 million for 12 AIG employees, the largest 

number of pay packages for any employees of the 3 companies. Only one 

AIG Top 25 employee was paid less than $2 million in 2012. 

Meanwhile, even though taxpayers are still owed a combined $36.2 billion18

for the investments in GM and Ally, both companies have attempted to get 

around the rules established to protect taxpayers by limiting excessive 

compensation for companies that are partially Government owned, and both 

companies have failed to appreciate how much pay they have already received 

under OSM.

GM:

GM officials complained about the pay restrictions in their 2012 proxy 

statement and in a meeting with the Treasury Secretary. In March 2012, 

weeks before the Acting Special Master set the 2012 pay packages, GM CEO 

Akerson met with Treasury Secretary Geithner, without the Acting Special 

Master, asking Treasury to release GM from OSM’s pay limits by lifting the 

more onerous TARP exceptional assistance pay restrictions that led to OSM’s 

jurisdiction.

19 Secretary Geithner rejected GM’s request. On April 26, 2012, 

GM filed a proxy statement stating that pay for GM’s CEO was not high 

enough and that the TARP pay restrictions restrict GM from paying its

executives sufficiently. In the proxy statement, GM complained about being 

limited to long-term restricted stock for incentive pay, rather than cash 

bonuses, and claimed that its inability under TARP to offer a competitive mix 

of cash and stock became an area of increasing concern. In particular, GM 

noted concerns with using restricted stock for several senior executives,

including CEO Akerson, the chief financial officer, an executive of GM 

Europe, and others. GM noted in the proxy statement that it had discussed its

concerns with the Acting Special Master. When OSM set pay packages for 

 18 As of December 31, 2012.

19 Companies remain under OSM’s jurisdiction as long as they are receiving TARP exceptional assistance.

According to the proxy statement, CEO Akerson’s total compensation for 2011 “falls in the lowest quartile of 

compensation for CEOs of comparable companies” and that the TARP pay restrictions are keeping GM from 

delivering compensation for critical personnel in a manner that will drive sustained long-term growth. 
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SIGTARP 13-001 January 28, 2013

GM for 2012, it removed the long-term restricted stock from four employees’ 

pay packages, including the pay package of CEO Akerson.

In February 2012, GM proposed that nine employees receive cash salary 

increases, one of which was a cash salary increase from $600,000 to $900,000 

for a GM Europe employee, despite that unit’s losses. OSM approved

approximately 70% of GM’s Top 25 employees to receive cash salaries 

exceeding market medians and almost 60% to receive total pay packages 

worth more than the 50th percentile. OSM also removed from GM CEO 

Akerson’s pay package incentive compensation tied to meeting performance 

criteria, shifting the same amount to stock salary that is earned immediately.

Ally:

SIGTARP previously reported that Ally’s CEO complained to SIGTARP 

about reducing the cash salary of one of his employees to $500,000. Ally 

executives pushed for high pay for their employees, despite knowing that 

then-Special Master Feinberg was concerned that most of Ally’s Top 25 

employees contributed to Ally’s need for a bailout.

Despite OSM having approved Ally’s request that approximately 90% of 

Ally’s Top 25 employees receive total pay packages exceeding the 50th

percentile, Ally requested a cash salary increase of $50,000 for an employee 

of ResCap, and a $91,000 cash salary increase for another Ally employee, 

both of which OSM approved. ResCap asked a bankruptcy judge to approve 

two compensation plans. The judge denied one of the compensation plans 

that provided for the award of between $4.1 million to $7 million in incentive 

payments for 17 ResCap employees. However, the judge approved a retention 

plan making 174 ResCap employees eligible to receive an aggregate 

$10.8 million in retention payments.
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 28

SIGTARP 13-001 January 28, 2013

Conclusions and Recommendations

While taxpayers struggle to overcome the recent financial crisis and look to 

the U.S. Government (“Government”) to put a lid on compensation for 

executives of firms whose missteps nearly crippled the U.S. financial system, 

the U.S. Department of the Treasury (“Treasury”) continues to allow 

excessive executive pay. American International Group, Inc. (“AIG”), Ally 

Financial Inc. (“Ally”), and General Motors Corporation (“GM”) executives 

continue to rake in Treasury-approved multimillion-dollar pay packages that 

often exceed guidelines from the Office of the Special Master for TARP 

Executive Compensation (“OSM”).20 

The Office of the Special Inspector General for the Troubled Asset Relief 

Program (“SIGTARP”) reported in January 2012 that the Special Master 

could not effectively rein in excessive compensation at companies that 

received exceptional assistance from the Troubled Asset Relief Program 

(“TARP”) from 2009 through 2011: The Special Master was under the 

constraint that his most important goal was to get the companies to repay and 

exit TARP, a goal that gave the companies leverage.21 Treasury’s formal 

response to SIGTARP’s report came from Acting Special Master Patricia 

Geoghegan, who stated that “OSM has succeeded in achieving its mission” by 

reducing pay for the Top 25 executives at these companies from the pay they 

received prior to TARP. 

Treasury’s success should not be judged based on reductions in pay from a 

time when these companies stood on their own without taxpayer assistance. If 

that is the definition of success, the work of OSM was effectively over when 

Special Master Kenneth R. Feinberg set the first pay packages in 2009, and 

there is no longer a need for a Special Master. Rather, Treasury’s success 

should be based on whether Treasury awards appropriate pay for executives 

while taxpayers continue to fund these companies’ bailouts. 

SIGTARP found that once again, in 2012, Treasury failed to rein in excessive 

pay. In 2012, OSM approved pay packages of $3 million or more for 54% of 

the 69 Top 25 employees at AIG, GM, and Ally – 23% of these top executives 

(16 of 69) received Treasury-approved pay packages of $5 million or more, 

 20 OSM’s primary responsibility is to set pay packages for the Top 25 employees at companies whose amount and 

nature of their TARP bailout were labeled “exceptional.” At the end of 2012, only three companies receiving 

exceptional assistance under TARP remained: AIG, GM, and Ally. 21 SIGTARP previously reported that, for 2009 through 2011, the Special Master approved multimillion-dollar 

compensation packages for Top 25 employees and approved pay packages worth $5 million or more over the 2009 

to 2011 period for 49 individuals of 7 companies.
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SIGTARP 13-001 January 28, 2013

and 30% (21 of 69) received pay ranging from $3 million to $4.9 million. 

Treasury seemingly set a floor, awarding 2012 total pay of at least 

$1 million.22

Taxpayers deserve transparency on Treasury’s decisions to award 

multimillion-dollar pay packages to executives at companies that had been 

stuck in TARP for four years. First, even though OSM set guidelines aimed at 

curbing excessive pay, SIGTARP previously warned that Treasury lacked 

robust criteria, policies, and procedures to ensure those guidelines are met. 

Treasury made no meaningful reform to its processes. Second, absent robust 

criteria, policies, and procedures to ensure its guidelines were met, OSM’s 

decisions were largely driven by the pay proposals of the same companies that 

historically, and again in 2012, proposed excessive pay. Third, with the 

companies exercising significant leverage, the Acting Special Master rolled 

back OSM’s application of guidelines aimed at curbing excessive pay. 

Despite SIGTARP’s previous warning that Treasury lacked robust criteria, 

policies, and procedures to ensure that Treasury’s guidelines to curb 

excessive pay are met, Treasury made no meaningful reform to its 

processes. 

Former Special Master Feinberg developed guidelines aimed at curbing 

excessive pay and reducing excessive risk taking. Treasury Secretary 

Timothy F. Geithner testified that executive compensation played a material 

role in causing the financial crisis because it encouraged excessive risk taking. 

Feinberg previously told SIGTARP that he limited cash salaries to $500,000 

and shifted compensation more toward stock to reduce excessive risk and 

keep employees’ “skin in the game.” Feinberg also previously told SIGTARP 

that he targeted total compensation at the 50th percentile for similarly situated 

employees at similarly situated entities to keep the companies competitive. 

Feinberg testified before Congress that he used long-term restricted stock tied 

to performance metrics to correct problems with executive compensation 

practices at these companies.

Although SIGTARP previously reported serious problems with OSM’s paysetting process and recommended fixes for those problems, Treasury failed to 

take any meaningful action in response. SIGTARP reported that OSM 

approved multimillion-dollar compensation packages, trying to shift these 

packages away from large cash salaries and toward stock, but that OSM did 

not have any criteria for applying its guidelines. SIGTARP reported that 

 22 Only one employee received Treasury-approved pay under $1 million. Treasury awarded this AIG employee a 

guaranteed cash salary of $700,000.
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SIGTARP 13-001 January 28, 2013

OSM awarded cash salaries greater than $500,000 without OSM 

substantiating good cause. The only action Treasury took in response to 

SIGTARP’s findings and recommendations was to document its use of market 

data on the 50th percentile and, in an eight-page spreadsheet, document 

limited explanations for cash salaries exceeding $500,000.

Despite SIGTARP’s previous warnings, Treasury did not establish meaningful 

criteria for having good cause to award cash salaries greater than $500,000. 

In 2012, OSM did not independently analyze the basis for awarding cash 

salaries greater than $500,000. Without this analysis, OSM put itself in the 

position of relying heavily on justifications by the companies – companies 

that historically have pushed back on the Special Master’s limitations on 

compensation, in particular, on cash salaries. By not making substantive 

changes, Treasury is clinging to the status quo of awarding multimillion-dollar 

pay packages.

OSM’s decisions were largely driven by the companies’ pay proposals, the 

same companies that historically, and again in 2012, proposed excessive 

pay, failing to appreciate the extraordinary situation they were in, with 

taxpayers funding and partially owning them. 

Many believe that AIG, Ally, and GM would not exist except for the 

Government assistance each so desperately requested. SIGTARP previously 

reported that, given OSM’s overriding goal to get the companies to repay 

TARP, the companies had significant leverage over OSM by proposing and 

negotiating for excessive pay, warning that if OSM did not provide 

competitive pay packages, top executives would leave and go elsewhere. This 

was also the case for 2012 pay. For 2012, AIG negotiated for Treasuryapproved pay of approximately $108 million for 25 employees, GM 

negotiated for Treasury-approved pay of $64 million for 23 employees, and 

Ally negotiated for Treasury-approved pay of approximately $78 million for 

21 employees. 

By proposing and negotiating for excessive 2012 pay, these executives 

continue to lack an appreciation for their extraordinary situations and fail to 

view themselves through the lenses of companies substantially owned by the 

Government. Other company actions or statements in 2012 shed light on the 

companies’ lack of appreciation for their extraordinary situation. AIG CEO 

Robert Benmosche, who has raked in the most compensation of any employee 

under OSM – $42 million in four years, with a cash salary exceeding by 200% 

the median salary of his peers – was quoted in New York Magazine as stating 

that neither Treasury nor the Federal Reserve Board has thanked him for

repaying AIG’s rescue package. GM CEO Dan Akerson asked Treasury 
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 31

SIGTARP 13-001 January 28, 2013

Secretary Geithner to relieve GM from OSM’s pay restrictions, a move 

Akerson said would ultimately benefit taxpayers, and issued a proxy statement 

complaining about the pay restrictions. Ally executives sought pay raises for 

the president of its subsidiary, Residential Capital, LLC (“ResCap”), despite 

the fact that ResCap filed bankruptcy in 2012 and sought extra pay for 

ResCap employees from the bankruptcy court. 

Absent robust policies, procedures, or criteria to implement OSM’s 

guidelines, in 2012, the Acting Special Master approved compensation largely 

driven by the three companies’ proposals. For example, OSM awarded 

$6.2 million in pay raises to 18 employees. Treasury approved a $1 million 

pay raise for the CEO of AIG’s Chartis subsidiary, a $200,000 pay raise for a 

ResCap employee – weeks before ResCap filed for bankruptcy – and a 

$100,000 pay raise for an executive at GM’s European unit, despite that unit 

experiencing significant losses. OSM’s written explanations for the pay raises 

lacked substance, largely parroting what each company asserted to OSM 

without any independent analysis by OSM. By requesting these pay raises, 

the companies failed to appreciate that they continued to be funded by 

taxpayers. 

With the companies having significant leverage, the Acting Special Master 

appears to have rolled back OSM’s application of guidelines. 

50th Percentile Guideline: In 2012, OSM did not follow its own guidelines 

aimed at curbing excessive pay by having total compensation generally not 

exceed the 50th percentile for similarly situated employees. Treasury 

awarded total pay packages exceeding the 50th percentile by approximately 

$37 million for approximately 63% of the Top 25 employees of AIG, GM, 

and Ally. The Acting Special Master appears to have rolled back the 

50th percentile guideline, telling SIGTARP, for example, that she set total 

compensation for all of Ally’s Top 25 employees between the 50th and 75th 

percentiles. 

Cash Salaries Limited to $500,000: OSM’s lack of meaningful criteria and 

independent analysis contributed to OSM’s rolling back its guideline to limit 

cash salaries to $500,000. In 2012, OSM approved cash salaries greater than 

$500,000 for one-third of the employees within OSM’s pay-setting

jurisdiction (23 of 69 Top 25 employees at AIG, GM, and Ally). 

Acting Special Master Geoghegan is not following former Special Master 

Feinberg’s final recommendation that she “limit guaranteed cash,” “demand a 

performance component for most compensation,” and “hold the line on cash 

salaries.” Feinberg testified before Congress that “...base cash salaries should 
TREASURY CONTINUES APPROVING EXCESSIVE PAY FOR TOP EXECUTIVES AT BAILED-OUT COMPANIES 32

SIGTARP 13-001 January 28, 2013

rarely exceed $500,000, and only then for good cause shown, and should be, 

in many cases, well under $500,000...” However, Acting Special Master 

Geoghegan told SIGTARP there is no cash salary cap, and $500,000 is a 

“discretionary guideline that is useful,” but there is no law or regulation that 

says she needs “a memo to permit a company to go above $500,000.” 

Never have there been so many exceptions to the $500,000 cash salary 

guideline for the number of people under the Acting Special Master’s 

jurisdiction as there were in 2012. The Acting Special Master increased the 

number of employees with Treasury-approved cash salaries greater than 

$500,000 from 22 employees in 2011 to 23 employees in 2012. The number 

has quadrupled from six employees in 2009, despite the fact that the number 

of companies OSM reviews decreased as companies repaid and exited TARP. 

In addition to questioning the approval of cash salaries in excess of $500,000 

for one-third of the employees, SIGTARP questions whether OSM is 

following the spirit of its $500,000 cash salary guideline. Although OSM 

guidelines target salaries greater than $500,000, notably in 2012, OSM 

allowed 25 employees to have cash salaries exactly at the $500,000 limit 

(falling outside OSM’s guideline by $1). Accordingly, OSM allowed cash 

salaries of $500,000 or more for 70% (48 of 69) of Top 25 employees at AIG, 

GM, and Ally. OSM allowed cash salaries of $450,000 or more for 94% (65 

of 69) of Top 25 employees at AIG, GM, and Ally. In stark contrast, the 2011 

median household income of U.S. taxpayers who fund these companies was 

approximately $50,000.

Similar to OSM’s explanations for approving pay raises, OSM’s 

“justifications” for good cause for cash salaries to exceed $500,000 largely 

parrot what each company asserted orally or in writing to OSM. Acting 

Special Master Geoghegan told SIGTARP that OSM does not perform an 

independent analysis, in part due to the 60-day constraint to issue a decision 

on the companies’ proposals (which come in February). OSM uses data 

supplied by the companies, talks to company officials and other Treasury 

officials, and looks at publicly available data. Because many of the same 

employees remained in the Top 25 from 2011 to 2012, OSM could have 

analyzed those employees’ responsibilities and value to the company 

throughout the year, and then could have used the end of the year information 

to supplement its existing information. OSM should not limit itself to perform 

its primary mission from February to early April, when it issued its 

determination memorandums. By using only the 60 days, OSM missed an 

opportunity to conduct an independent analysis that could have limited pay 

raises and high cash salaries.
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SIGTARP 13-001 January 28, 2013

More importantly, the Acting Special Master appears to have no desire to 

independently analyze whether good cause exists to award an employee a cash 

salary greater than $500,000. The Acting Special Master told SIGTARP that 

it would be “utterly normal” for these individuals in the Top 25 to expect over 

$500,000 in cash salary. That might be true if the companies had not been 

bailed out and were not still significantly owned by taxpayers. Acting Special 

Master Geoghegan said OSM “does not spend that much time on a small 

decision like whether to continue to give this person $600,000.” She 

described taking an extra two hours to look at this person’s pay justification to 

see whether there was “added responsibility” as a “waste of time.” She said 

she did not think that when the $500,000 guideline was formulated, it would 

take an “independent little project” to determine when someone should go 

above $500,000. If the pay czar is not even willing to independently analyze 

high cash salaries for 23 employees, who else will protect taxpayers?

The Acting Special Master told SIGTARP that OSM would not normally 

reopen executive compensation from year to year because it would be 

disruptive, and it is “relatively easy for OSM to keep things the way they 

were.” The Acting Special Master largely based her decisions on prior years’ 

pay, telling SIGTARP that OSM would not change pay based on a change in 

circumstances. However, even where there was a negative change such as 

ResCap filing bankruptcy or GM Europe suffering significant losses, OSM 

did not reduce the compensation for the employees in charge of those entities.

Long-Term Restricted Stock: By removing long-term restricted stock from 

some executives’ pay and using it only in half of the pay packages, the Acting 

Special Master is effectively removing a key OSM guideline aimed at 

reducing excessive risk by tying individual compensation to long-term 

company success. She also removed long-term restricted stock for senior 

executives, including the CEOs of AIG, GM, and Ally, calling it “a burden” to 

compensate them with long-term restricted stock “that has no value.” 

However, Treasury’s Rule states that the portion of performance-based 

compensation compared to total compensation should be greater for positions 

that exercise high levels of responsibility. After making her decisions on pay 

in April 2012, she subsequently removed long-term restricted stock for all of 

Ally’s Top 25 employees on the basis that the company’s subsidiary, ResCap, 

had filed bankruptcy, and that the company had announced it was exploring 

strategic alternatives such as a possible sale of international operations. 

However, only three employees in Ally’s Top 25 worked at ResCap and OSM 

knew in April that ResCap was planning a restructuring. In addition, both 

GM and AIG were selling international operations.
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SIGTARP 13-001 January 28, 2013

The guidelines originally created by former Special Master Feinberg were 

aimed at fixing the material role executive compensation played in causing the 

financial crisis by encouraging excessive risk taking. By not holding the line 

on large cash salaries (awarding $500,000 or more to 70% of the executives 

under OSM’s pay-setting jurisdiction, and allowing 94% of employees to be 

paid cash salaries of $450,000 or more), and removing long-term, incentivebased stock as requested by the companies, OSM is effectively relinquishing 

some of OSM’s authority to the companies, which have their own best 

interests in mind. The Acting Special Master told SIGTARP that OSM is not 

the compensation committee. SIGTARP agrees – the compensation 

committee looks out for the interest of the company. The Office of the 

Special Master’s job is to look out for the interests of taxpayers, which it 

cannot do if it continues to rely to a great extent on the companies’ proposals 

and justifications without conducting its own independent analysis.

There are two lessons to be learned from OSM’s 2012 pay-setting process and 

decisions:

First, guidelines aimed at curbing excessive pay are not effective, absent 

robust policies, procedures, or criteria to ensure that the guidelines are met. 

This is the second report by SIGTARP to warn that the Office of the Special 

Master, after four years, still does not have robust policies, procedures, or 

criteria to ensure that pay for executives at TARP exceptional assistance 

companies stays within OSM’s guidelines. Perhaps the Acting Special Master 

thinks that OSM has already succeeded in achieving its mission by limiting 

compensation for these executives from pre-TARP levels or believes that 

OSM’s existing processes are sufficient. The question is whether it is 

sufficient for taxpayers. Treasury continues to award excessive pay packages, 

including large guaranteed cash salaries. Meaningful reform is still possible 

because GM and Ally remain under OSM’s jurisdiction. Without meaningful 

reform, including independent analysis by OSM, Treasury risks that TARP 

companies could potentially misuse taxpayer dollars for excessive executive 

compensation.

Second, while historically the Government has not been involved in pay 

decisions at private companies, one lesson of this financial crisis is that 

regulators should take an active role in monitoring and regulating factors that 

could contribute to another financial crisis, including executive compensation 

that encourages excessive risk taking. According to OSM, OSM’s authority 

to set pay for AIG executives has ended. SIGTARP previously reported that 

AIG CEO Benmosche told SIGTARP that the Special Master’s practices 

would have no lasting impact. He also said, however, that pay and 

performance must be linked, and if the majority of income is fixed, or 
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guaranteed, then pay is not linked to performance. Given AIG’s considerable 

pushback on OSM’s limitations on pay as reported in SIGTARP’s prior 

report, it is highly likely that AIG could return to past compensation practices. 

The responsibility shifts to the Federal Reserve Board to ensure that AIG does 

not encourage excessive risk taking through compensation. 
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Recommendations

SIGTARP recommends:

1. Each year, Treasury should reevaluate total compensation for those 

employees at TARP exceptional assistance companies remaining in the 

Top 25 from the prior year, including determining whether to reduce total 

compensation. 

2. To ensure that Treasury effectively applies guidelines aimed at curbing 

excessive pay and reducing risk taking, Treasury should develop policies, 

procedures, and criteria for approving pay in excess of Treasury 

guidelines.

3. Treasury should independently analyze whether good cause exists to 

award a Top 25 employee a pay raise or a cash salary over $500,000. To 

ensure that the Office of the Special Master has sufficient time to conduct 

this analysis, Treasury should allow OSM to work on setting Top 25 pay 

prior to OSM’s receiving the company pay proposals, which starts the 60-

day timeline.

4. To be consistent with Treasury’s Interim Final Rule that the portion of 

performance-based compensation compared to total compensation should 

be greater for positions that exercise higher levels of responsibility, 

Treasury should return to using long-term restricted stock for employees, 

particularly senior employees such as CEOs. 
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Management Comments and 

SIGTARP’s Response

Treasury provided an official written response to a draft of this report in a 

letter dated January 25, 2013, which is produced in full in Appendix H. 

OSM’s letter states, in part, that “Although we disagree with [SIGTARP’s] 

findings and conclusions, OSM benefitted from the audit review.”

OSM’s response set forth what OSM considers its accomplishments since 

2009. OSM stated that the draft report contained many inaccuracies, and that 

it provided “500 comments and edits” showing that OSM “disagrees with

numerous issues” in the report. OSM responded that its decisions on 2012 

pay were consistent with guidelines and Treasury’s Interim Final Rule. OSM 

responded that it has criteria for not using long-term restricted stock.

SIGTARP considered OSM’s comments (which were significantly less than 

500 and largely repetitive) and addressed the comments in the report, as 

necessary and appropriate. OSM did not to point to specific factual 

inaccuracies in the report; rather, OSM took a different view of the relevance 

of the facts raised by SIGTARP and SIGTARP’s conclusions. For instance, 

OSM did not have any written criteria on the use of long-term restricted stock 

prior to setting pay for 2012. Instead, the Acting Special Master told 

SIGTARP the reasons why she stopped using this important guideline for half 

of the employees.

Treasury did not agree to implement any of the recommendations contained in 

the report, only to consider the recommendations. As we concluded in the 

report, OSM’s job is to look out for the interests of taxpayers, which it cannot 

do if it continues to rely to a great extent on executive compensation proposals 

and justifications submitted by the same companies that historically have 

proposed excessive pay, without conducting its own robust, independent 

analyses of appropriate pay for TARP exceptional assistance companies.
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Appendix A – Objectives, Scope, and Methodology

SIGTARP performed this evaluation under the authority of the Emergency Economic 

Stabilization Act of 2008 and Public Law 110-343, as amended, which also incorporates the 

duties and responsibilities of inspectors general under the Inspector General Act of 1978, as 

amended. SIGTARP evaluated the Special Master’s decisions on executive compensation at 

AIG, Ally, and GM, the three companies remaining in TARP that had received exceptional 

financial assistance.23 

Our specific objectives were to assess OSM’s process and determinations for 2012 pay packages 

for the Top 25 most highly compensated AIG, Ally, and GM employees, and to evaluate OSM’s 

progress in implementing SIGTARP’s recommendations set forth in SIGTARP evaluation report 

12-001, “The Special Master’s Determinations for Executive Compensation of Companies 

Receiving Exceptional Assistance Under TARP,” issued January 23, 2012. 

The scope of the evaluation covered the Acting Special Master’s 2012 determination process and 

included the Top 25 most highly compensated employees. The evaluation began in March 2012 

and ended in January 2013, and was performed in Washington, D.C. To evaluate OSM’s 

decisions and its progress in implementing our recommendations, SIGTARP interviewed OSM 

officials and reviewed OSM’s 2012 determinations and supporting documentation for 69 Ally, 

AIG, and GM Top 25 employees.

SIGTARP evaluated whether OSM followed its guidelines to limit cash and total compensation. 

To identify criteria that OSM used to evaluate executive compensation, SIGTARP reviewed the 

Emergency Economic Stabilization Act of 2008, the American Recovery and Reinvestment Act 

of 2009, TARP Standards for Compensation and Corporate Governance; Interim Final Rule, and 

Congressional testimony. 

SIGTARP conducted this evaluation in accordance with the “Quality Standards for Inspection 

and Evaluation” established by the Council of the Inspectors General on Integrity and Efficiency. 

Those standards require that SIGTARP plan and perform the evaluation to obtain evidence 

sufficient to provide a reasonable basis for findings and conclusions based on the evaluation 

objectives. SIGTARP believes that the evidence obtained provides a reasonable basis for the 

findings and conclusions based on the evaluation objectives.

Limitations on Data

SIGTARP relied upon Treasury to identify and provide email communication and documents 

related to the executive compensation determination process. It is possible that the 

documentation provided by Treasury did not reflect a comprehensive response to SIGTARP’s 

documentation requests, potentially limiting SIGTARP’s review.

 23 AIG repaid its Government assistance in December 2012.
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Use of Computer-Processed Data

SIGTARP did not use computer-processed data during this evaluation. SIGTARP obtained data 

from determination memorandums that are available to the public on Treasury’s website.

Internal Controls

To assess internal controls over OSM’s determination process, SIGTARP interviewed OSM staff 

and requested OSM’s policies and procedures to determine the extent to which policies and 

procedures existed, and whether internal controls were reasonable and effective.

Prior Coverage

On January 23, 2012, SIGTARP issued evaluation report 12-001, “The Special Master’s 

Determinations for Executive Compensation of Companies Receiving Exceptional Assistance 

Under TARP.” This report addresses the process OSM designed to set pay packages and OSM’s 

decisions on compensation for the Top 25 employees at the companies that received exceptional 

assistance under TARP. Under this evaluation, SIGTARP assessed the criteria used by OSM to 

evaluate and make determinations on each company’s executive compensation packages and 

whether OSM consistently applied criteria for the determinations made in 2009, 2010, and 2011.

On October 14, 2009, SIGTARP issued audit report 10-002, “Extent of Federal Agencies’ 

Oversight of AIG Compensation Varied, and Important Challenges Remain.” This report 

addresses the extent of knowledge and oversight by Federal Reserve and Treasury officials over 

AIG compensation programs and, specifically, payments to retain employees in the AIG 

Financial Products (“AIGFP”) unit. The report also addresses the extent to which executive 

compensation restrictions or preexisting contractual obligations governed AIGFP retention 

payments, the outstanding AIG compensation issues requiring resolution, and Government 

actions to address them. 

On August 19, 2009, SIGTARP issued audit report 09-003, “Despite Evolving Rules on 

Executive Compensation, SIGTARP Survey Provides Insights on Compliance.” This report 

addresses the efforts of TARP recipients to comply with executive compensation restrictions and 

plans to comply with subsequently enacted changes in requirements.
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Appendix B – AIG Determinations
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Appendix C – Ally Determinations

The following table is from Ally’s April 6, 2012 Determination memorandum. After Ally 

subsidiary ResCap filed for bankruptcy, OSM removed long-term restricted stock from all Ally 

employee pay packages, not just ResCap employees, replacing long-term restricted stock with 

stock salary, which vests immediately.
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Appendix D – GM Determinations
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Appendix E – Principles of TARP Standards for 

Compensation and Corporate Governance; Interim 

Final Rule

Principle Definition

Risk The compensation structure should avoid incentives to take unnecessary or 

excessive risks that could threaten the value of the TARP recipient, 

including incentives that reward employees for short-term or temporary 

increases in value, performance, or similar measure that may not ultimately 

be reflected by an increase in the long-term value of the TARP recipient. 

Accordingly, incentive payments or similar rewards should be structured to 

be paid over a time horizon that takes into account the risk horizon so that 

the payment or reward reflects whether the employee’s performance over 

the particular service period has actually contributed to the long-term value 

of the TARP recipient.

Taxpayer 

Return

The compensation structure, and amount payable where applicable, should 

reflect the need for the TARP recipient to remain a competitive enterprise, 

to retain and recruit talented employees who will contribute to the TARP 

recipient’s future success, and ultimately to be able to repay TARP 

obligations.

Appropriate 

Allocation

The compensation structure should appropriately allocate the components of 

compensation such as salary, short-term and long-term incentives, as well as 

the extent to which compensation is provided in cash, equity, or other types 

of compensation such as executive pensions, other benefits, or perquisites, 

based on the specific role of the employee and other relevant circumstances, 

including the nature and amount of current compensation, deferred 

compensation, or other compensation and benefits previously paid or 

awarded. The appropriate allocation may be different for different positions 

and for different employees, but generally, in the case of an executive or

other senior-level position, a significant portion of the overall compensation 

should be long-term compensation that aligns the interest of the employee 

with the interests of shareholders and taxpayers.

PerformanceBased 

Compensation

An appropriate portion of the compensation should be performance based 

over a relevant performance period. Performance-based compensation 

should be determined through tailored metrics that encompass individual 

performance and/or the performance of the TARP recipient or a relevant 

business unit, taking into consideration specific business objectives. 

Performance metrics may relate to employee compliance with relevant 

corporate policies. In addition, the likelihood of meeting the performance 

metrics should not be so great that the arrangement fails to provide an 
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adequate incentive for the employee to perform, and performance metrics 

should be measurable, enforceable, and actually enforced if not met. The 

appropriate allocation and the appropriate performance metrics may be 

different for different positions and for different employees, but generally a 

significant portion of total compensation should be performance-based 

compensation, and generally that portion should be greater for positions that 

exercise higher levels of responsibility.

Comparable 

Structures and 

Payments

The compensation structure, and amount payable where applicable, should 

be consistent with, and not excessive, taking into account compensation 

structures, and amounts for persons in similar positions or roles at similar 

entities that are similarly situated, including, as applicable, entities 

competing in the same markets and similarly situated entities that are 

financially distressed or that are contemplating or undergoing 

reorganization.

Employee 

Contribution to 

TARP Recipient 

Value

The compensation structure, and amount payable where applicable, should 

reflect the current or prospective contributions of an employee to the value 

of the TARP recipient, taking into account multiple factors such as revenue 

production, specific expertise, compliance with company policy and 

regulation (including risk management), and corporate leadership, as well as 

the role the employee may have had with respect to any change in the 

financial health or competitive position of the TARP recipient.
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Appendix F – Acronyms and Abbreviations

Acronym or Definition

Abbreviation

AIG American International Group, Inc.

Ally Ally Financial Inc. (formerly General Motors Acceptance Corporation, 

Inc.)

GM General Motors Corporation

IFR TARP Standards for Compensation and Corporate Governance; Interim 

Final Rule (also “Treasury’s Rule”)

OSM Office of the Special Master for TARP Executive Compensation

ResCap Residential Capital, LLC (Ally Financial Inc.’s mortgage subsidiary)

SIGTARP Office of the Special Inspector General for the Troubled Asset Relief 

Program

TARP Troubled Asset Relief Program

Top 25 the five senior executive officers and the next 20 most highly compensated 

employees

Treasury U.S. Department of the Treasury
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Appendix G – Evaluation Team Members

This evaluation was conducted and the report was prepared under the direction of Kurt W. Hyde,

Deputy Special Inspector General for Audit and Evaluation, and Bruce Gimbel, Acting Assistant 

Deputy Special Inspector General for Audit and Evaluation, Office of the Special Inspector 

General for the Troubled Asset Relief Program.

Staff members who conducted the evaluation and contributed to the report include Craig Meklir, 

Vonda Batts, Jennifer Principe, Meredith McDaniel, Brandon Crowder, Michelle Mang, Janice 

Turner, Yusuf House, Tracy Davis-Ross, and Cynthia Broome.
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Appendix H – Management Comments
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SIGTARP Hotline

If you are aware of fraud, waste, abuse, mismanagement, or misrepresentations associated with the 

Troubled Asset Relief Program, please contact the SIGTARP Hotline.

By Online Form: www.SIGTARP.gov By Phone: Call toll free: (877) SIG-2009

By Fax: (202) 622-4559

By Mail: Hotline: Office of the Special Inspector General

for the Troubled Asset Relief Program

1801 L Street., NW, 3rd Floor

Washington, D.C. 20220

Press Inquiries

If you have any inquiries, please contact our Press Office:

Troy Gravitt

Director of Communications

Troy.Gravitt@treasury.gov

202-927-8940

Legislative Affairs

For Congressional inquiries, please contact our Legislative Affairs Office:

Joseph Cwiklinski

Director of Legislative Affairs

Joseph.Cwiklinski@treasury.gov

202-927-9159

Obtaining Copies of Testimony and Reports

To obtain copies of testimony and reports, please log on to our website at www.SIGTARP.gov.