There is significant new guidance covering employees who have a "higher risk of unreasonable compensation." Following FAR 31.205-6(b)(2) that provides special consideration of compensation for certain employees, DCAA has prepared guidance that applies to these "higher risk" employees. In general, employees who can exercise influence over their level of compensation are considered high risk and include owners, partners or individuals having a substantial financial interest in the company and their family members as well as executives, officers and board members of companies who are not necessarily owners. Though there are no hard and fast rules determining what represents influence, the guidance alludes to the SEC threshold of 10 percent or more of voting stock representing the ability to exercise influence.

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