America is in the midst of a regulatory “czar” craze. According to a recent news report, President Barack Obama has “nearly three dozen czars in his administration, managing everything from closing the Guantanamo Bay detention facility to ending the genocide in Darfur.”1 The word “czar” has Russian origins, and is defined as “a person with great power in a particular area.”2

Of the newly appointed American “czars,” the one with perhaps the highest profile is the “compensation czar,” attorney Kenneth R. Feinberg, who is best known for serving as the Special Master of the Federal September 11th Victim Compensation Fund of 2001. In June 2009, under the authority of an Interim Final Rule (IFR) called Troubled Asset Relief Program (TARP) Standards for Compensation and Corporate Governance,3 U.S. Secretary of the Treasury Timothy Geithner appointed Mr. Feinberg as the Special Master for TARP Executive Compensation.