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Brian Hughes

Director at CompoSecure
Board

About Brian F. Hughes

Independent director of CompoSecure, Inc. since December 27, 2021; age 66. Former audit partner at KPMG (2002–2019) and Arthur Andersen (1981–2002). Serves on CMPO’s Audit Committee and is designated an SEC “audit committee financial expert”; holds an MBA and BS in Economics/Accounting from Wharton and a CERT Certificate in Cybersecurity Oversight (Carnegie Mellon SEI) .

Past Roles

OrganizationRoleTenureCommittees/Impact
KPMG LLPAudit Partner; National private markets group leader; VC co-leader2002–2019Led private markets and VC audit practices; deep accounting/audit expertise
Arthur AndersenAudit Partner1981–2002Big Four pedigree; complex audit and capital markets experience

External Roles

OrganizationRoleTenureCommittees/Impact
Bentley Systems (Nasdaq: BSY)Director; Audit Committee ChairCurrentLeads audit oversight as chair
Innovid Corp. (NYSE: CTV)Director; Audit Committee ChairCurrentLeads audit oversight as chair

Board Governance

  • Independence: Board has affirmed Hughes is independent under Nasdaq standards; also designated “audit committee financial expert” .
  • Committee memberships evolution:
    • 2023: Audit Committee Chair; Compensation Committee Member; 100% board and committee attendance for all directors in 2023 .
    • As of Dec 31, 2024: Audit Committee Member; no director attended fewer than 75% of meetings in 2024 .
    • 2025: Audit Committee Member; Audit Chair role held by Joseph J. DeAngelo .
Governance MetricFY 2023FY 2024 (as of 12/31)2025 (Record Date 4/3/25)
Independence (Nasdaq)Independent Independent Independent
Audit CommitteeChair Member Member (Chair: DeAngelo)
Compensation CommitteeMember Not listed as member Not listed as member
Attendance (Board/Committees)100% (all directors) ≥75% (all directors) n/a (not stated)
  • Controlled company context: Resolute/Tungsten owns ~50.5% voting power; CMPO relies on certain Nasdaq “controlled company” exemptions (e.g., compensation and nominating committees not all independent) . Compensation Committee currently includes a non-independent employee director (Thomas R. Knott) .

Fixed Compensation

  • Cash retainer framework:
    • Pre–Sept 2024: Board $50,000; Audit Chair $20,000; Compensation Chair $15,000; Nominating Chair $10,000; Audit Member $10,000; Compensation Member $7,500; Nominating Member $5,000 .
    • Post–Oct 1, 2024: Board $50,000; Audit Chair $25,000; Committee member fees eliminated (only chair retainers remain) .
Director Cash Earned (USD)20232024
Brian F. Hughes – Fees Earned or Paid in Cash$77,500 $95,625

Performance Compensation

  • Equity program shift for directors:
    • Pre–Oct 2024: Annual RSU grants $150,000; initial RSU $150,000 for new directors; RSUs vest fully at next annual meeting or 1-year anniversary .
    • Post–Oct 1, 2024: Annual stock options $200,000; initial option $200,000 for new directors; options vest in four equal annual installments; exercise price at grant-date fair market value; prior RSU recipients received “Continuing Director Uplift” option grants to bridge to the $200,000 annual level .
Equity Award Details20232024
Stock Awards (fair value)$150,000 RSUs $150,000 RSUs
Option Awards (fair value)$0 $33,333 “Continuing Director Uplift” options
Underlying RSU shares outstanding (12/31)n/a stated by count11,783 shares
Underlying option shares outstanding (12/31)n/a4,649 options
Option strike pricen/a$7.17 (Hughes)
Option vestingn/a25% per year over 4 years

No performance-vested director awards were disclosed; director equity vests time-based .

Other Directorships & Interlocks

CompanySectorRoleCommittee
Bentley Systems (BSY)Infrastructure engineering softwareDirectorAudit Chair
Innovid (CTV)Advertising/analytics technologyDirectorAudit Chair

Expertise & Qualifications

  • SEC “audit committee financial expert”; extensive accounting/audit background from KPMG and Arthur Andersen .
  • Cybersecurity governance training (CERT Certificate in Cybersecurity Oversight) .
  • Wharton MBA; BS in Economics/Accounting (Wharton) .
  • Skills matrix attributes include financial literacy and accounting/audit; public company board experience .

Equity Ownership

  • Stock ownership guidelines: Non-employee directors must hold shares equal to 5× annual cash retainer; expected to meet within five years (includes vested and unvested time-based RSUs; excludes options). As of 2023, all participants met guidelines .
Ownership MetricApr 10, 2024Apr 3, 2025
Beneficial ownership – Class A shares71,886 (<1%) 94,229 (<1%)
Outstanding director RSUs (12/31 prior year)n/a by date-specific11,783
Outstanding director options (12/31 prior year)n/a by date-specific4,649 (strike $7.17)
Hedging/pledging policyProhibits hedging/shorts; pledging requires GC pre-clearance (2024) Prohibits speculative trading/hedging; short sales prohibited (2025)

Fixed Compensation (Detail)

ComponentAmount/Policy
Board annual cash retainer$50,000
Audit Committee Chair retainer$20,000 (pre-Sept 2024); $25,000 (post-Oct 1, 2024)
Committee member feesAudit $10,000; Comp $7,500; Nominating $5,000 (pre-Sept 2024); eliminated for members post-Oct 1, 2024 (chairs only)

Performance Compensation (Detail)

ComponentGrant ValueInstrumentsVestingNotes
Annual director equity (pre–Oct 2024)$150,000RSUs1 year or to next annual meetingRSU conversion/deferral program existed pre–Sept 2024
Annual director equity (post–Oct 2024)$200,000Stock options25% per year over 4 yearsExercise price at FMV; “Option Conversion Program” allows cash retainer conversion into options; deferral discontinued
Hughes 2024 awards (reported)$150,000 RSUs; $33,333 optionsRSUs & optionsRSUs per prior policy; options per uplift4,649 options at $7.17; 11,783 RSUs outstanding at 12/31/24

Governance Assessment

  • Positives

    • Independent director with deep audit and capital markets experience; SEC-designated financial expert; chairs audit committees at two public companies—strong audit oversight credentials .
    • Attendance: The board reported full compliance in 2023 and no director below 75% in 2024—indicates engagement .
    • Stock ownership alignment: Mandatory director ownership guidelines (5× retainer); all participants met by year-end 2023 .
  • Watch items / potential red flags

    • Controlled company status: Majority ownership (~50.5%) by Tungsten/Resolute grants governance exemptions; may reduce minority shareholder influence .
    • Compensation Committee composition: Includes non-independent employee director (Thomas R. Knott) under controlled-company exemptions—could dilute independence of pay oversight (Hughes is not currently on this committee) .
    • Board interlocks/family ties: John D. Cote (director) is son of Executive Chairman David M. Cote—heightened related-party vigilance; Audit Committee (including Hughes) reviews related-party transactions .
    • Delegation of equity issuance authority to Resolute Holdings for M&A and awards (via Letter Agreement) could centralize decision-making; governance processes disclosed mitigate with committee oversight .
  • Mitigations

    • Audit Committee responsibilities explicitly include reviewing related-party transactions, internal controls, and cybersecurity oversight; Hughes is a member and designated financial expert .

Overall, Hughes’ audit pedigree, independent status, and external audit chair roles support board effectiveness in financial oversight; controlled-company dynamics and committee independence exemptions warrant continued monitoring .