Looking at our LO compensation in light of the 10% rule in Reg Z.....

Does anyone have any suggestions of how to determine the value of restricted stock or stock options awarded as a bonus? My HR department is telling me that they have no value at the time they are awarded; only when they are exercised or vested. However, I believe they need to be considered in the bonus calculation - it's spelled out clearly that they should be included.

Curious how other banks are doing this.