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James J. Bender

Director at TWO HARBORS INVESTMENT
Board

About James J. Bender

Independent director at Two Harbors Investment Corp. (TWO) since 2013; age 68. Chair of the Nominating & Corporate Governance Committee and member of the Compensation Committee; affirmed independent by the Board. Education: B.A. in Mathematics (St. Olaf College) and J.D. (University of Minnesota Law School). Prior public company executive/legal leadership across energy infrastructure and pipelines informs his governance and regulatory expertise .

Past Roles

OrganizationRoleTenureCommittees/Impact
WPX Energy, Inc. (NYSE: WPX)President & CEO; DirectorDec 2013 – May 2014Led energy E&P company; governance and capital markets oversight .
WPX Energy, Inc.SVP, Special ProjectsMay 2014 – Jul 2014Transition leadership on strategic projects .
WPX Energy, Inc.SVP & General CounselApr 2011 – Dec 2013Corporate governance and regulatory matters .
The Williams Companies, Inc.General Counsel & Corporate SecretaryDec 2002 – Dec 2011Public company governance, disclosure, and compliance .
Williams Partners GP LLC (general partner of Williams Partners L.P.)General CounselSep 2005 – Dec 2011Oversight of MLP governance/legal .
General partner of Williams Pipeline Partners L.P.General Counsel2007 – Aug 2010Pipeline partnership legal leadership .

External Roles

OrganizationRoleTenureNotes
Shell Midstream Partners, L.P. (NYSE: SHLX)Director of the general partnerOct 2014 – Oct 2022Energy midstream board service .
Apco Oil & Gas International Inc. (NASDAQ: APAGF)Director & ChairmanDec 2013 – Aug 2014Affiliate of WPX Energy .
Orion Infrastructure Capital (private)Senior Advisory Board MemberUntil Jun 2023Private equity advisory (non-public) .
Other Public Company Boards (current)20250 current public boards .

Board Governance

  • Committee assignments: Compensation (member) and Nominating & Corporate Governance (Chair). All Board committees are fully independent .
  • Independence: Board affirmatively determined Bender meets NYSE independence standards .
  • Attendance: Board met 5 times in 2024; committees met AC 6, CC 3, NCGC 2, ROC 1. Each director attended at least 75% of aggregate Board and applicable committee meetings; all then-current directors attended the May 2024 annual meeting .
  • Executive sessions: Independent directors meet regularly in executive session without management .
  • Leadership: Independent Chairperson of the Board (Stephen G. Kasnet) separate from CEO .

Fixed Compensation

Component2024 AmountNotes
Annual cash retainer$98,000Paid quarterly .
Committee chair fee (NGCG Chair)$15,000Cash; applicable to Chairs of CC/ROC/NCGC .
Total cash paid (Bender)$113,000Per Summary of 2024 Independent Director Compensation .
Annual RSU grant value$117,988Granted May 15, 2024 under 2021 Plan; closes at $12.96/share .
Total compensation (Bender)$230,988Cash + stock awards .
  • Director compensation mix is cash plus equity. RSUs for directors fully vest at the next annual meeting, with pro‑rata vesting upon early termination (except death/disability full vest); double-trigger vesting upon change-of-control if service ends within 24 months or if awards are not assumed by the acquirer .

Performance Compensation

ItemDetail
Performance-linked payNot applicable to independent directors; director equity is time-based RSUs (no TSR/financial performance conditions) .
RSU grant dateMay 15, 2024 .
RSU shares (Bender)9,104 RSUs (based on grant-date value) .
Vesting scheduleFully vests at next annual meeting; pro-rata if service ends mid-term; full vest on death/disability .
Change-of-controlDouble-trigger: full vest if service ends within 24 months post-CoC; immediate vest if awards not assumed by resulting entity .
OptionsCompany did not grant options/SARs in 2024 and currently does not grant such awards .

Other Directorships & Interlocks

CompanyRoleInterlock/Transactions
No related party transactions in 2024; Audit Committee reviews and oversees related party transactions .
Compensation Committee InterlocksNone; no insider participation or cross-board interlocks involving TWO executives .

Expertise & Qualifications

  • Corporate governance and regulatory expertise; deep experience advising and leading public companies and partnerships in energy and infrastructure .
  • Education: B.A. in Mathematics (St. Olaf); J.D. (University of Minnesota Law School) .
  • Board qualifications noted by TWO: governance proficiency, regulatory knowledge, and public company board experience .

Equity Ownership

MetricAmountNotes
Shares beneficially owned (as of Mar 19, 2025)35,860Includes RSUs scheduled to vest within 60 days; RSUs are not outstanding and have no voting rights until vest .
RSUs included (within 60 days)9,104Included in beneficial count per SEC Rule 13d-3; not counted as outstanding .
% of common shares outstanding<1%Based on 104,022,948 shares outstanding .
Hedging/pledgingProhibited for directors and officers .
Director stock ownership guidelineMay not sell if holdings would be < $300,000 market value; up to 40% of vesting shares may be sold for taxes .

Shareholder Voting Support (Director Elections)

YearForAgainstAbstainBroker Non-Votes
202556,846,0276,275,846218,26818,537,902
202453,423,13110,896,780298,62616,604,806
  • Advisory say-on-pay support: 2024 approval ~95.6% of votes cast; 2025 vote totals 60,761,479 For vs 2,154,569 Against (and 424,093 Abstain), indicating continued broad support for compensation program .

Insider Trades

PeriodResult
2023-01-01 to 2025-11-20No Form 4 transactions found for “James J. Bender” at TWO (insider-trades skill query result).

Governance Assessment

  • Positives:
    • Independent director with 12 years of service; Chair of Nominating & Corporate Governance Committee, providing direct oversight of board composition, governance policies, CSR, and sustainability matters .
    • Strong governance framework: majority-independent board; independent Chair; regular executive sessions; declassified board; majority vote standard with resignation policy .
    • Attendance and engagement: met at least 75% attendance; directors encouraged to attend annual meetings; Bender’s committees met regularly (CC 3; NCGC 2) in 2024 .
    • Alignment features: director equity grants; stock ownership guidelines with $300k floor; prohibition on hedging/pledging; no related party transactions reported in 2024 .
    • Compensation governance: independent Compensation Committee advised by independent consultant (Pay Governance) with no conflicts; robust clawback policy updated for NYSE rules .
  • Red flags / watch items:
    • Elevated “Against” votes relative to other nominees in both 2024 and 2025 (Bender had the highest opposition counts each year among nominees), indicating a subset of shareholder concerns; continued monitoring of vote trends warranted .
    • No current public company board roles (reduces outside interlocks; neutral), but prior energy midstream affiliations should be monitored for any future related-party exposure; none disclosed for 2024 .

Overall, Bender’s legal and governance background, committee leadership, and independence support board effectiveness at TWO, with shareholder vote signals to monitor. High say-on-pay approvals and strict anti-hedging/pledging and ownership guidelines reinforce alignment, while absence of related-party transactions reduces conflict risk .