Attached files
file | filename |
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10-K - FORM 10-K - MONARCH COMMUNITY BANCORP INC | k50252e10vk.htm |
EX-23 - EX-23 - MONARCH COMMUNITY BANCORP INC | k50252exv23.htm |
EX-14 - EX-14 - MONARCH COMMUNITY BANCORP INC | k50252exv14.htm |
EX-21 - EX-21 - MONARCH COMMUNITY BANCORP INC | k50252exv21.htm |
EX-32 - EX-32 - MONARCH COMMUNITY BANCORP INC | k50252exv32.htm |
EX-99.1 - EX-99.1 - MONARCH COMMUNITY BANCORP INC | k50252exv99w1.htm |
EX-31.2 - EX-31.2 - MONARCH COMMUNITY BANCORP INC | k50252exv31w2.htm |
EX-31.1 - EX-31.1 - MONARCH COMMUNITY BANCORP INC | k50252exv31w1.htm |
Exhibit 99.2
Monarch Community Bancorp, Inc. UST 447
I, Rebecca S. Crabill, certify, based on my knowledge, that:
(i) The compensation committee of Monarch Community Bancorp, Inc., has discussed, reviewed, and
evaluated with senior risk officers at least every six months during any part of the most recently
completed fiscal year that was a TARP period, senior executive officer (SEO) compensation plans
and employee compensation plans and the risks these plans pose to Monarch Community Bancorp, Inc.,
except for approximately 8 months from March 2010 until November 16, 2010;
(ii) The compensation committee Monarch Community Bancorp, Inc. has identified and limited during
any part of the most recently completed fiscal year that was a TARP period any features of the SEO
compensation plans that could lead SEOs to take unnecessary and excessive risks that could threaten
the value of Monarch Community Bancorp, Inc. and has identified any features of the employee
compensation plans that pose risks to Monarch Community Bancorp, Inc. and has limited those
features to ensure that Monarch Community Bancorp, Inc. is not unnecessarily exposed to risks;
(iii) The compensation committee has reviewed, at least every six months during any part of the
most recently completed fiscal year that was a TARP period, except for approximately 8 months from
March 2010 until November 16, 2010, the terms of each employee compensation plan and identified any
features of the plan that could encourage the manipulation of reported earnings of Monarch
Community Bancorp, Inc. to enhance the compensation of an employee, and has limited any such
features;
(iv) The compensation committee of Monarch Community Bancorp, Inc. will certify to the reviews of
the SEO compensation plans and employee compensation plans required under (i) and (iii) above;
(v) The compensation committee of Monarch Community Bancorp, Inc. will provide a narrative
description of how it limited during any part of the most recently completed fiscal year that was a
TARP period the features in:
(A) SEO compensation plans that could lead SEOs to take unnecessary and excessive risks that could
threaten the value of Monarch Community Bancorp, Inc.;
(B) Employee compensation plans that unnecessarily expose Monarch Community Bancorp, Inc. to risks;
and
(C) Employee compensation plans that could encourage the manipulation of reported earnings of
Monarch Community Bancorp, Inc. to enhance the compensation of an employee;
(vi) Monarch Community Bancorp, Inc. has required that bonus payments to SEOs or any of the next
twenty most highly compensated employees, as defined in the regulations and guidance established
under section 111 of EESA (bonus payments), be subject to a recovery or
clawback provision during any part of the most recently completed fiscal year that was a TARP
period if the bonus payments were based on materially inaccurate financial statements or any other
materially inaccurate performance metric criteria;
(vii) Monarch Community Bancorp, Inc. has prohibited any golden parachute payment, as defined in
the regulations and guidance established under section 111 of EESA, to a SEO or any of the next
five most highly compensated employees during any part of the most recently completed fiscal year
that was a TARP period;
(viii) Monarch Community Bancorp, Inc. has limited bonus payments to its applicable employees in
accordance with section 111 of EESA and the regulations and guidance established thereunder during
any part of the most recently completed fiscal year that was a TARP period;
(ix) Monarch Community Bancorp, Inc. and its employees have complied with the excessive or luxury
expenditures policy, as defined in the regulations and guidance established under section 111 of
EESA, during any part of the most recently completed fiscal year that was a TARP period; and any
expenses that, pursuant to the policy, required approval of the board of directors, a committee of
the board of directors, an SEO, or an executive officer with a similar level of responsibility were
properly approved;
(x) Monarch Community Bancorp, Inc. will permit a non-binding shareholder resolution in compliance
with any applicable federal securities rules and regulations on the disclosures provided under the
federal securities laws related to SEO compensation paid or accrued during any part of the most
recently completed fiscal year that was a TARP period;
(xi) Monarch Community Bancorp, Inc. will disclose the amount, nature, and justification for the
offering, during any part of the most recently completed fiscal year that was a TARP period, of any
perquisites, as defined in the regulations and guidance established under section 111 of EESA,
whose total value exceeds $25,000 for any employee who is subject to the bonus payment limitations
identified in paragraph (viii);
(xii) Monarch Community Bancorp, Inc. will disclose whether Monarch Community Bancorp, Inc., the
board of directors of Monarch Community Bancorp, Inc., or the compensation committee of Monarch
Community Bancorp, Inc. has engaged during any part of the most recently completed fiscal year
that was a TARP period a compensation consultant; and the services the compensation consultant or
any affiliate of the compensation consultant provided during this period;
(xiii) Monarch Community Bancorp, Inc. has prohibited the payment of any gross-ups, as defined in
the regulations and guidance established under section 111 of EESA, to the SEOs and the next twenty
most highly compensated employees during any part of the most recently completed fiscal year that
was a TARP period;
(xiv) Monarch Community Bancorp, Inc. has substantially complied with all other requirements
related to employee compensation that are provided in the agreement between Monarch Community
Bancorp, Inc and Treasury, including any amendments;
(xv) Monarch Community Bancorp, Inc. has submitted to Treasury a complete and accurate list of the
SEOs and the twenty next most highly compensated employees for the current fiscal year, with the
non-SEOs ranked in descending order of level of annual compensation, and with the name, title, and
employer of each SEO and most highly compensated employee identified; and
(xvi) I understand that a knowing and willful false or fraudulent statement made in connection with
this certification may be punished by fine, imprisonment, or both. (See, for example, 18 USC
1001.)
/s/ Rebecca S. Crabill
|
Date: March 18, 2011 | |||
(Principal Financial Officer) |
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