The proposed RBI rules also mandate compensation clawbacks in cases of misreporting of bad loans and failure to adequately provision for bad loans. While most compensation contracts at private banks have a clawback option in cases of gross negligence or a breach of integrity by the CEO, it is rarely invoked. It is only recently, in the case of ICICI Bank, that its board approved a clawback on all performance bonuses paid to its former CEO, Chanda Kochhar, between April 2009 to March 2018 after she was accused of violating the Bank's code of conduct.