Consistent with the Federal Reserve Board’s principles for safety and soundness, the firm’s controls include (i) sizing the incentive compensation pool to more fully consider risk-adjusted returns, compliance with risk limits and the market and competitive environment; (ii) allocating the incentive compensation pool among business areas, taking into account the businesses’ returns on certain financial, capital and risk metrics; and (iii) increasing, generally for more senior-level employees, the level of year-end deferrals subject to multiyear clawback and cancellation provisions.