I'd be interested to hear your thoughts, actually.  Perhaps this is blindingly obvious, but I think that pre-crisis pay regulation was often focused on disclosure, and done through the SEC.  So called say on pay, one of the potential reforms of the crisis, is, if you like, disclosure with an exclamation point. 

Empirically proving this would be very difficult, but it seems to me that disclosure does not shrink pay packages, which, I assume, was one of the goals of requiring it.

The corporate governance move in pay, I think, was to do more of it through options, and longer horizon payouts, which were designed to align the executive's interest with those of the owners.  This did the opposite of shrinking pay packages, though it may have been a good idea.

One thing we have seen from the crisis is what happens when you limit pay, instead of disclosing it or long terming it.  Cutting pay packages, as the US did as an owner, through its pay czar, and also, as a result, making future compensation uncertain - that has been a stunning penalty for financial intermediaries, and one they will move heaven and earth to avoid.  Limiting pay looks to me like a forceful discipline of management.

Again, this may be obvious, but it suggests to me that pay regulation can be a tool that owners and regulators could use to great effect on banks.  I'm not sure that pay disclosure, however, makes much of a difference, consistent though it is with the SEC's ethos.

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