Wall Street reform may be what the Dodd-Frank Act is intended to accomplish, but as usual, those financial institutions that followed the rules and operated with the best interests of their customers in mind end up shouldering a new burden because of a bunch of bad actors who didn't.

The Office of the Comptroller of the Currency, the Federal  Reserve, the FDIC, the Office of Thrift Supervision , the SEC, the FHFA and the NCUA have jointly prescribed an interagency rule to implement Section 956 of Dodd-Frank.

Under the NCUA's version of the proposed interagency rule, credit union boards will have to ratchet up board and management knowledge, oversight and policymaking on executive compensation. The rule will directly affect all credit unions with more than $1 billion in assets. Fundamentally, the rule applies to less than 200 credit unions out of approximately 7,500 nationwide. These billion plus credit unions will have to report to the NCUA on their executive incentive compensation practices, methodology and the underlying assumptions about how they structure incentive or "at risk" pay for their executives.

• Under the rule, all credit unions with $1 billion or more in assets must:
• Develop and maintain sound incentive compensation policies,
• Submit reports on executive incentive compensation to the NCUA annually,
• Avoid providing "excessive" compensation, and

Construct incentives so that they don't encourage executives to take "inappropriate risks" that could lead to material loss.