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Matthew S. Stark

Chief Legal and Compliance Officer and Corporate Secretary at Open Lending
Executive

About Matthew S. Stark

Matthew S. Stark is Chief Legal and Compliance Officer and Corporate Secretary at Open Lending (LPRO) since November 15, 2023, after serving as General Counsel and Corporate Secretary from January 2021; he holds a B.A. in History (University of Utah) and a J.D. (University of Texas School of Law) . Company performance during his tenure includes 2023 net income of $22.1 million and adjusted EBITDA of $50.2 million, with total shareholder return (TSR) based on a $100 investment at $61.89 for 2023 (2021: $163.49; 2022: $49.09) . In Q1 2024 leadership transition, he received a $35,000 discretionary bonus for exemplary performance .

Past Roles

OrganizationRoleYearsStrategic Impact
Open Lending (LPRO)Chief Legal & Compliance Officer; Corporate SecretaryNov 15, 2023–presentElevated to oversee legal/compliance; corporate governance responsibilities
Open Lending (LPRO)General Counsel; Corporate SecretaryJan 2021–Nov 2023Led corporate legal matters and secretary responsibilities

External Roles

OrganizationRoleYearsStrategic Impact
Forestar Group Inc. (NYSE)General Counsel & SVPOct 2015–Jan 2021General Counsel of a NYSE-listed company
David Weekley HomesAssistant General CounselNov 2013–Oct 2015Senior legal responsibilities at major homebuilder
KB Home (NYSE)Senior Regional CounselMar 2006–Nov 2013Regional counsel at publicly traded homebuilder

Fixed Compensation

Metric202220232024
Salary (incl. commissions) ($)$312,703 $370,423 $373,149
Commission included ($)$17,703 $20,423 $23,149
Derived Base Salary ($)$295,000 (312,703−17,703) $350,000 (370,423−20,423) $350,000 (373,149−23,149)
All Other Compensation ($)$9,150 $9,900 $10,350

Notes: Salary figures include commissions per proxy footnotes; base salary derived arithmetically from disclosed components .

Performance Compensation

Annual Cash Incentive (Bonus)

Metric20232024
Target bonus (% of salary)50% — (not disclosed)
Target bonus ($)$175,000 — (not disclosed)
Actual payout ($)$124,250 $78,575
% of base salary35.5% 22.5%
% of target earned71% 44.9%
Discretionary bonus ($)$0 $35,000

Bonus Performance Metrics (Company-level; drives NEO payouts) – 2023

Performance MetricWeightThresholdTargetMaximumActual ResultActual Attainment
Revenue ($mm)20% $111.1 $148.1 $185.1 $117.5 59%
Adjusted EBITDA ($mm)20% $58.0 $77.3 $96.6 $50.2 0%
Cash EBITDA ($mm)20% $60.1 $80.2 $100.2 $87.5 118%
Higher of New Accounts vs OTS/Cert Volume20% 64/2,309 85/3,079 106/3,849 44/2,770 80%
Revenue from New Initiatives20% N/A N/A N/A Yes 100%
Total100% 71%

Definitions: Adjusted EBITDA excludes interest, taxes, D&A, and share-based comp; Cash EBITDA defined per proxy .

Long-Term Incentives (Equity)

Grant DateTypeWeightTargeted Award Value ($)# of Shares
Apr 5, 2024Time-based RSUs67% $170,236 30,952
Apr 5, 2024Performance-based RSUs33% $106,051 19,282
Total (2024 LTI)Mixed (RSUs + PSUs)$276,287 50,234

Design shift: In 2023, Stark’s LTI was 100% time-based RSUs; in 2024, PSUs were added (33%), improving pay-for-performance alignment .

Equity Ownership & Alignment

Beneficial Ownership

As-of DateShares Beneficially Owned% of Shares Outstanding
Mar 28, 202428,160 <1%
Mar 27, 202559,425 <1%
  • Hedging/pledging: Insiders are prohibited from pledging shares on margin, short sales, and hedging/derivative transactions unless approved by the Audit Committee .
  • Clawback: Company adopted a clawback policy on Oct 26, 2023 (Nasdaq Rule 5608), requiring recoupment of erroneously awarded incentive comp over a 3-year lookback in the event of certain restatements ; reaffirmed policy compliance in 2025 proxy .
  • Options: No options or similar instruments were granted to executive officers in 2024 .

Outstanding Equity Awards (as of Dec 31, 2023)

Grant DateTypeUnvested Units (#)Market Value ($)Vesting Schedule (first installment)
Jan 4, 2022Time-based RSUs11,922 $101,456 Time-based RSUs; schedule as per plan (footnote (9))
Oct 19, 2022Time-based RSUs54,905 $467,242 Four equal annual installments beginning Oct 19, 2023
Mar 15, 2023Time-based RSUs46,130 $392,566 Four equal annual installments beginning Mar 15, 2024

Market value based on $8.51 closing price on Dec 29, 2023 .

Employment Terms

ScenarioCash Severance ($)Pro Rata Bonus ($)Acceleration of TB RSUs ($)Acceleration of PSUs ($)Benefits ($)Total ($)
Death/Disability$0 $0 $0 $0 $0 $0
Termination (without cause / with good reason)$0 $0 $0 $0 $0 $0
Change-in-Control & Qualifying Termination$0 $0 $657,303 $115,113 $0 $772,416

Notes: Equity acceleration amounts calculated at $5.97 closing price on Dec 31, 2024; PSUs assumed at target level for unvested awards . CIC appears double-trigger (requires qualifying termination) .

Investment Implications

  • Alignment: Introduction of PSUs in 2024 (33% weighting) enhances pay-for-performance linkage; annual bonuses tied to revenue, EBITDA, Cash EBITDA, and growth metrics with transparent thresholds/targets .
  • Retention and selling pressure: Multi-year RSU vesting schedules (2022–2023 grants vest over four years) create ongoing vesting events that may lead to periodic sales; Stark has no cash severance, reducing “golden parachute” value and potentially increasing mobility risk vs peers .
  • Governance safeguards: Strict prohibitions on hedging/pledging and an active clawback policy (Nasdaq 5608) mitigate adverse alignment behaviors; no options granted in 2024 reduces leverage risk .
  • Ownership: Beneficial ownership is modest (<1%), suggesting alignment relies more on unvested and ongoing RSU awards than large outright holdings .
  • Execution indicator: A $35,000 discretionary bonus in 2024 for leadership transition support signals board confidence in Stark’s role during management changes .