Seems like there's a glaring loophole there. Let's say they want to pay their top five people ten million dollars each. And let's say they can think of five VP-level people who should be earning around $500K each. Why not say "Oh, these VPs are crucial to our survival. They're worth $20 million a year. Sadly, we can only pay them $500K of that." At that point, the VPs get about what they would normally get, and the traders can safely be paid $10 million a year.
Or am I misunderstanding the cap?