Benefits consultants say it remains unclear exactly how the government's introduction last October of the Troubled Asset Relief Program will affect card issuers' executive-compensation plans. The American Recovery and Reinvestment Act of 2009 Congress passed in February mandates new executive-compensation rules and restrictions for financial institutions operating with TARP funds. Most large card issuers, including Bank of America Corp. and Citigroup Inc., accepted TARP money. But the U.S. Department of the Treasury has not yet issued final details on how the new rules will be applied. "It's a complicated situation with a lot of moving parts," Don Nemerov, an executive director with compensation-benefits consultancy Grant Thornton LLP, tells Cards&Payments, a CardLine sister publication. The number of executives potentially affected by new compensation rules varies based on how much TARP money the institution accepts, he notes. In general, senior executives at institutions operating with TARP funds may receive only restricted stock, not cash, as bonuses. Employers also are limited in how much of a top executive's pay they can deduct and how much severance they can give departing executives, and they need more transparency and oversight of executive-compensation packages by independent committees, Nemerov says. Many card issuers are eager to return their TARP funds as soon as possible because they are uncomfortable with such compensation restrictions, says Brian Riley, a research director at TowerGroup, an independent research firm owned by MasterCard Advisors. "Issuers want to regain leverage over how they run their companies and reward their employees because it's one of the key ways for them to remain competitive," Riley says. But card execs hoping for fatter paychecks could be waiting awhile, he adds. "Even without TARP, card execs' bonuses are tied to revenues, and industry revenues are on the way down," Riley says. "It's pretty ugly right now for card executives hoping for a big raise."