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UNITED STATES Published: 2018-10-25 12:40:35

... Recoupment Provisions ("Clawbacks") ......RECOUPMENT PROVISIONS ("CLAWBACKS") We have clarified our policy regarding "Recoupment ...
Corporate and Securities Update Published: 2010-08-03 12:43:19

... access; and * a requirement to adopt clawback policies with respect to employment ... Enhanced Clawback Requirements for Executives. Public companies will be required to adopt ...
3/18/24, 10:37 AM Key Considerations ... Published: 2024-03-18 10:38:42

...tatements?utm_source=vuture&u... 3/21 2. Clawback Considerations if retirement eligibility ... that companies have adopted the required clawback policies, they should update the ...
Glen R. Johnson | James C. Tory | Rima Ramchandani Published: 2019-04-12 18:58:07

companies to disclose information about clawbacks of executive compensation and about the ... Say-on-pay, compensation clawbacks and well-being The CBCA gives directors the power to ...
Authors: Peter W. Baldwin, Erica H. MacDonald, Daniel E. Pulliam... Published: 2023-03-07 17:39:12

on Compensation Clawbacks and Personal Device Messaging 1 | DOJ Announces Corporate Compliance Policy Changes and Provides New Guidance on Compensation Clawbacks and Personal ...
©2005-2023 K&L Gates LLP. All Rights Reserved. Published: 2023-05-15 11:51:20

and certain significant limited partner clawbacks; (b) details about a fund's investment ... Below are the notable modifications to Section 4: Question 82 - Clawbacks Large private ...
ATLANTA CHICAGO CINCINNATI CLEVELAND COLUMBUS DAYTON NEW YORK... Published: 2023-01-09 13:52:04

... Updated Cover Page Check Boxes. The SEC's new clawback disclosure rules amend annual ... received by any of the company's executive officers during the relevant clawback period. ...
Disclosure Developments and 2022 Form_10-K Disclosure Locator Published: 2023-03-01 17:21:30

for the recently adopted SEC clawback rule 10. Required EDGAR submission of ... to $1.235 billion.  On the Horizon: Clawbacks  The SEC has adopted a "clawback" ...
http://www.dpw.com/1485409/newsletters/generalcounsel/04.21.09... Published: 2009-04-21 23:18:18

... Recoupment of Compensation ("Clawbacks") What happens to a bonus that is "earned" and ... Historically, the answer has usually been "nothing". A limited form of "clawback" was ...
C:\Documents and Settings\Kim a Published: 2007-07-05 11:34:38

special meetings this proxy season. "Clawback" and golden parachute resolutions also ... Meanwhile, "clawback" proposals averaged 35.5 percent support at six firms where voting ...
A Spotlight on the SEC's Agenda (CE Nov-Dec 2022) Published: 2025-01-19 12:04:35

... to Rule 10b5-1 and the Dodd-Frank Act clawback requirements (see the September-October 2022 issue of The Corporate Executive at page 1 for more on the new SEC clawback rules). ...
The SEC Is Going After Lawyers : TheCorporateCounsel.net Blog Published: 2012-05-30 07:11:08

Solicitation 4. The Latest SEC Actions & CD&A Developments: Compensation Advisors, Clawbacks, Pay Disparity & More 5. Refining Your Pay-for-Performance Message & Addressing the ...
Hedging & Pledging Policies: Possible Approaches & Survey : TheCorpora... Published: 2015-02-18 07:29:18

However, the TSR sector medians in ISS' reports are updated monthly and align with the subject company's fiscal year end. Clawbacks: SEC Gets $500k from Pair of Ex-CFOs Here's news ...
Glass Lewis Issues '19 Voting Guidelines : TheCorporateCounsel... Published: 2018-10-26 16:28:58

will consider excise tax gross-ups, severance and sign-on arrangements, grants of front-loaded awards, clawback provisions, and CD&A disclosure for smaller reporting companies. ...
Executive Pay: CII Policy Overhaul Says to "Get Back to Basics... Published: 2019-09-19 07:43:05

The new policy also broadens its approach to clawbacks - adding to the list of appropriate recovery events "personal misconduct or ethical issues that cause, or could cause, ...
Just Posted: Notes from the 2008 JCEB Meeting with the SEC Staff... Published: 2008-09-11 05:35:54

... clawback provision with "teeth" - as laid out in our Winter 2008 issue of Compensation Standards. The WSJ article cites statistics of the growing numbers of companies with clawback ...
The SEC and Treasury on Executive Compensation Practices : TheCorporat... Published: 2009-06-11 06:50:14

compensation on longer-term performance and thereby obviating the need for specific clawbacks, while encouraging the holding of equity awards for longer periods. 3. Compensation ...
The Dodd Bill: Weighing In at a Portly Six Pounds : TheCorporateCounse... Published: 2010-03-16 08:44:27

- Disclosure of executive pay vs. performance (Section 953, pages 876-877) - Clawbacks (Section 954, pages 877-878) - Disclosure of executive and director hedging (Section ...
Dave & Marty on Apache, Proxy Disclosure Trends and Jobs : TheCorporat... Published: 2010-03-12 08:57:06

required to adopt listing standards giving regulators and investors authority to clawback incentive-based compensation from executives if the company has a restatement due to ...
The Dodd-Frank Act: A Moving Target? Not Yet a Done Deal : TheCorporat... Published: 2010-07-01 09:34:52

Share Awards Subject to Discretion - You Can't Buy a Ferrari with Grant Date Fair Value - SEC Secures Victory in Clawback Case - Executive Pay and Risk Our July Eminders is Posted! ...
House's "Financial Choice Act": Enough to Choke a Horse : TheCorporate... Published: 2016-06-16 15:39:55

No sooner do I blog about a House bill that would make it challenging for the SEC to conduct any rulemaking, than Cooley's Cydney Posner blogs about an executive summary of the ...
Are Any Updates Necessary to Board Committee Charters This Year... Published: 2023-10-25 06:58:23

Further, the compensation committee charter should be revised to indicate any role that the committee plays in the administration of the company's stock exchange-compliant clawback ...
Glass Lewis Issues '24 Voting Guidelines : TheCorporateCounsel... Published: 2023-11-20 14:12:19

... Clawback Provisions - In addition to meeting listing requirements, effective clawback policies should provide companies with the power to recoup incentive compensation from an ...
2025 Benchmark Policy Guidelines Published: 2024-11-19 10:01:17

... 60 Recoupment Provisions (Clawbacks) ......to an executive that does not include a clawback provision and the company had a material ...
Course Materials Published: 2023-11-16 09:42:00

... Compliance Programs, Compensation Clawbacks and National Security" - Hunton (3/23) ... Analysis DOJ Announcements on Corporate Compliance Programs, Compensation Clawbacks and ...
Preparing your 2023 Form 20-F Published: 2023-11-29 17:23:30

... for public companies for further detail. Clawback rule The SEC adopted final rules in ... to adopt and comply with a written clawback policy requiring public companies to ...
DOJ Announces Major Changes to Corporate Compliance Program Evaluation... Published: 2023-03-07 16:09:14

Program on Compensation Incentives and Clawbacks (Pilot Program) requiring companies to ... also announced DOJ's new Pilot Program Regarding Compensation Incentives and Clawbacks. ...
2025 Benchmark Policy Guidelines Published: 2025-03-21 12:08:41

... 60 Recoupment Provisions (Clawbacks) ......to an executive that does not include a clawback provision and the company had a material ...
Two More Say-on-Pay Lawsuits Dismissed: Jacobs Engineering and... Published: 2012-03-20 07:06:47

Whether to implement a clawback if they haven't already Last week, 20 members of Congress sent this letter to the SEC urging the agency to prioritize the pay disparity rulemaking. ...
Filing Boo-Boo Stories: "Have You Heard About the One..." : TheCorpora... Published: 2012-10-31 07:24:11

In the letters, CII provided draft language and supporting commentary. Recently, CII members approved revisions to their clawbacks policy and an anti-forced arbitration clause ...
The Crystal Ball: What Might Top the SEC's Agenda? : TheCorporateCouns... Published: 2013-03-28 09:42:56

... hedging, pay versus performance and clawback - should remain on the agenda (to the ... demonstrate pay for performance, and clawbacks have become a fixture at many companies ...
Tomorrow's Pre-Conference Webcast: "Pay Ratio Workshop - What... Published: 2017-07-19 07:32:40

A Conversation with Nell Minow 12. Proxy Access: Tackling the Challenges 13. Clawbacks: What to Do Now 14. Dealing with the Complexities of Perks 15. The Big Kahuna: Your ...
SEC's Budget Seeks Cybersecurity Boost : TheCorporateCounsel... Published: 2018-02-13 06:45:28

... pay is structured & administered? 5. Clawbacks aren't just for restatements anymore. What is the latest thinking on applying clawbacks to a broader range of activities and a ...
#MeToo: Still Making Waves : TheCorporateCounsel.net Blog Published: 2020-08-14 07:22:33

The complaint references "cause" because Easterbrook's separation agreement incorporates clawback provisions from the company's standard severance plan, which require repayment if ...
Tech Glitch Prompts SEC to Reopen Comments on 11 Rulemaking Proposals... Published: 2022-10-11 07:49:52

Off the top of my head, it appears that the only major proposals that aren't affected by this are the SEC's clawbacks proposal and its Rule 10b5-1 proposal. According to the SEC's ...
SEC Posts IFRS Proposing Release : TheCorporateCounsel.net Blog Published: 2007-07-03 06:37:49

Among the notable developments with these proposals was more shareholder support for "clawback" proposals, which generally call for recouping payments made to executives in the ...
Examples: Companies Trying to Increase Voting Levels : TheCorporateCou... Published: 2010-03-08 07:42:57

... publicly disclosed that they maintain a "clawback policy" has significantly increased over ... have disclosed that they have adopted clawback polices that became effective in 2009. ...
Buybacks & Rule 10b-18: Targeted by Legislation & Investors Exchange... Published: 2018-04-12 07:35:06

6. Navigating ISS & Glass Lewis 7. Proxy Disclosures: The In-House Perspective 8. Clawbacks: What to Do Now 9. Dealing with the Complexities of Perks 10. Disclosure for ...
"Do Not Cross the Boss" : TheCorporateCounsel.net Blog Published: 2025-01-14 07:24:35

... That takes care of one aspect of the required Sarbanes-Oxley clawback (in this case, the ... The SEC is not one to let any prong of a SOX 304 clawback slip by, so it brought a claim ...
Proxy Disclosure & Executive Compensation Conferences: "Early... Published: 2022-06-13 07:20:30

Pay-for-Performance: Latest Updates 15. Dealing with the Complexities of Perks 16. Clawbacks: Where Things Stand 17. The Evolving Compensation Committee 18. Hot Topics: 30 ...
White Collar: DOJ Revises Corporate Criminal Enforcement Policies... Published: 2022-09-20 07:20:40

As Liz blogged yesterday over on CompensationStandards.com, Monaco also addressed how the DOJ will consider corporate compensation programs & clawback policies in criminal ...
Cooley Ale Published: 2010-07-20 20:20:36

... awarded com- pensation policy (clawback policy) X Exemption from SOX 404(b) for ... Recovery of erroneously awarded compensation policy (clawback policy) (Section 954) A new ...
GUIDELINES UNITED STATES PROXY PAPER(tm) AN OVERVIEW OF THE GLASS... Published: 2016-11-18 18:04:13

... Recoupment Provisions ("Clawbacks") ......to an executive that does not include a clawback provision and the company had a material ...
PROXY PAPER(tm) GUIDELINES AN OVERVIEW OF THE GLASS LEWIS APPROACH... Published: 2017-11-27 11:57:23

... Recoupment Provisions ("Clawbacks") ......to an executive that does not include a clawback provision and the company had a material ...
UNITED STATES Published: 2019-11-04 17:32:25

... Recoupment Provisions ("Clawbacks") ......an ex- ecutive that does not include a clawback provision and the company had a material ...
UNITED STATES Published: 2020-11-24 18:20:53

... Recoupment Provisions ("Clawbacks") ......an ex- ecutive that does not include a clawback provision and the company had a material ...
Microsoft Word - Corp Gov_Exec Comp_Update_07022010.doc Published: 2010-07-02 17:29:05

committees and their advisers; * clawback requirements for incentive compensation ... within 360 days of enactment. Expanded Clawback Requirements * The Act requires the SEC ...
OFFICE OF THE NEW YORK CITY COMPTROLLER SCOTT M. STRINGER | 1... Published: 2017-01-24 14:51:03

13 Prompting Executive Pay Clawbacks at Wells Fargo ......PROMPTING EXECUTIVE PAY CLAWBACKS AT WELLS FARGO In a September 22, 2016 letter, the ...
2019 PROXY SEASON REVIEW By Shirley Westcott July 2019 Overview Published: 2019-08-08 12:49:37

The compensation lineup produced two majority votes on clawback provisions, which saw a ... at Mallinckrodt on the disclosure of misconduct clawbacks and lobbying expenditures. ...
Broad Changes to CBCA Proposed: ... Published: 2019-04-12 19:11:38

on diversity and on compensation clawback mechanisms and the well-being of ... corporation (i.e., clawbacks) and "the well-being of employees, retirees and pensioners". ...