“Although the overall pay rule is tougher than previous versions, it is certainly still more benign relative to European rules,” said Alan Johnson, managing director of Johnson Associates Inc, a compensation consultant serving financial services firms, referring to the proposal.

He said the four-year deferral period “is not overly restrictive.” But the clawback could prove “onerous” since it covers activities of seven years.

“However, the real issue is how it will be determined and who will enforce the clawback?” he said. “Will the government have a role and how consistent will the application be?”

Reuters / April 21, 2016