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Results from: TheCorporateCounsel.net

Clawback Rule Timing in the Spotlight : TheCorporateCounsel.net... Published: 2023-04-06 06:04:38

as issuers seek to implement compliant clawback policies within the 60-day window ... for comments on the NYSE and Nasdaq clawback proposals, asking that the SEC not ...
Whether 8-K should be filed regarding approval of clawback policy... Published: 2023-12-01 01:22:15

approval of clawback policy Topic: Last Post: 12/1/2023 7:22:15 AM Subscribe Unsubscribe As many of you surely know, the deadline for approving a clawback policy pursuant to ...
The DOJ Focuses on Clawbacks (CE May-Jun 2023) Published: 2025-01-19 12:04:35

XXXVII, No. 2 May - June 2023 The DOJ Focuses on Clawbacks The SEC is not the only government agency concerned with the implementation of effective compensation clawback policies. ...
NYSE Posts Clawback Rule Filing : TheCorporateCounsel.net Blog Published: 2023-02-23 06:39:33

clawback policy requirements of the rule to all listed companies, with only limited exceptions. Under the rule, each listed company will ultimately be required to adopt a clawback ...
Contemplating Clawbacks: We Have Come a Long Way : TheCorporateCounsel... Published: 2022-10-25 06:03:31

clawback rules and pay versus performance? Partly because they had other more pressing things on their agenda, and perhaps partly because they recognized that both the clawback ...
Making a Case for Compliance-Based Incentive Comp to Supplement... Published: 2014-06-26 11:40:00

to supplement statutorily mandated clawback provisions (the "stick") as a way to ... determination that statutorily mandated clawback arrangements may be alone insufficient ...
NYSE and Nasdaq Propose Clawback Listing Standards (CE Jan-Feb... Published: 2025-01-19 12:04:35

XXXVII, No. 1 January-February 2023 NYSE and Nasdaq Propose Clawback Listing Standards In ... that will apply the disclosure and clawback policy requirements of the rule to all ...
Course Materials Published: 2023-12-06 19:11:52

"More on Clawbacks: Action Items and Implementation Considerations" Thursday, November 16, 2023 Course Materials 1 "More on Clawbacks: Action Items and Implementation ...
Making the Most of Clawback Provisions (CE Jan-Feb 2009) Published: 2025-01-19 12:04:31

The Corporate Executive, Vol. XXIII, No. 1 January-February 2009 Making the Most of Clawback Provisions Clawback policies (and such provisions in executive compensation ...
Dodd-Frank Clawbacks: NYSE Extends Effective Date! : TheCorporateCouns... Published: 2023-06-07 07:05:47

about fitting approval of a Dodd-Frank clawback policy into full compensation committee ... 1st to adopt a compliant Dodd-Frank clawback policy and that the policy would cover ...
Taxation of Compensation Disgorged Due to Securities Law Violations... Published: 2025-01-19 12:04:33

Taxation of Compensation Disgorged Due to Securities Law Violations (and Clawbacks?) Illuminating Case on the Tax Effect of Forfeitures and Clawbacks One of the many unresolved ...
cash retention bonus with clawback: Q & A/ Discussion Forum Published: 2009-02-24 02:37:53

Topic # 4591 1 reply cash retention bonus with clawback Topic: Last Post: 2/24/2009 ... Reply 2/24/2009 6:55:49 AM Replies: RE: cash retention bonus with clawback I think that it ...
Dodd-Frank Clawbacks: SEC Extends Period to Act on Exchange Rules... Published: 2023-04-26 06:32:39

for taking action on proposed listing standards to implement Dodd-Frank clawback rules. ... That will start the 60-day clock for listed companies to adopt a compliant clawback policy ...
Dodd-Frank Clawbacks: SEC Approves Amended Exchange Proposals... Published: 2023-06-12 00:35:08

proposed amendments to their listing standards to implement the Dodd-Frank clawback rules. ... December 1, 2023 to adopt compliant clawback policies and that they'll apply to ...
The Wells Fargo Clawback: Innovative - & Wave of the Future?... Published: 2016-09-29 09:43:57

These actions by the board more than effectuate what the company's clawback policy would have otherwise required. The look of clawbacks going forward, perhaps? Here's the related ...
The SEC's Clawback Proposing Release: 198 Pages : TheCorporateCounsel... Published: 2015-07-02 09:13:38

to direct the stock exchanges to adopt clawback listing standards, as required by ... We're posting memos in our "Clawbacks" Practice Area (see this Gibson Dunn blog). All five ...
Clawback Rules: What's Next? : TheCorporateCounsel.net Blog Published: 2022-10-27 05:00:37

Thankfully, you will not have to come up with a new clawback policy quickly in response to the new rules. The SEC's Fact Sheet notes the following timetable for the new rules and ...
SEC and DOJ Focus on Clawbacks : TheCorporateCounsel.net Blog Published: 2022-10-25 06:03:38

targeting executive compensation clawbacks. The Dechert memo notes: - The SEC is aggressively pursuing SOX 304 compensation clawbacks from Chief Executive Officers and Chief ...
Managing Restatements of Financial Results (CC Nov-Dec 2022) Published: 2025-01-19 12:04:20

but the SEC's adoption of new rules on clawback listing standards targeting compensation ... Clawback Policies. The SEC recently issued rules requiring the exchanges to implement ...
Managing a Clawback_ Agenda Items for t...ter a Restatement ... Published: 2024-02-16 09:52:06

performance disclosure and clawbacks - to improve voting outcomes and protect your board. ... Partner, Gibson Dunn & Crutcher LLP This program will cover: * Clawbacks * Pay vs. ...
Clawback Provisions for Legal Fees of Convicted Officers : TheCorporat... Published: 2005-05-24 06:46:37

A week or so ago, the WSJ carried an article about Merrill Lynch's decision about paying millions of dollars in legal fees for former officers that had been convicted of ...
Transcript: "Clawbacks - What Now After the SEC's Proposal" ... Published: 2015-07-27 07:38:21

We have posted the transcript for our popular CompensationStandards.com webcast: "Clawbacks - What Now After the SEC's Proposal." Proxy Access: Comments on the SEC's Review of ...
Contemplating Potential Dodd-Frank Clawback Exposure : TheCorporateCou... Published: 2015-09-24 14:00:50

On the heels of the SEC's controversial clawback proposal (see this convenient Fact Sheet), Audit Analytics provides some context and color around the potential clawback exposure ...
Quasi-Clawback: Goldman Discloses Rare Possible Forfeiture Due... Published: 2019-02-05 07:28:16

So these aren't true "clawbacks" - they're potential forfeitures of unpaid amounts, which are much easier for a company to administer. Remember that a few years ago in a different ...
SEC Adopts the Dodd-Frank Era Clawback Rules : TheCorporateCounsel... Published: 2022-10-27 14:30:59

Yesterday, the SEC adopted the clawback rules contemplated by Section 10D of the Exchange ... will have to adopt and comply with a clawback policy that conforms to these new rules, ...
Nasdaq Posts Clawback Rule Filing : TheCorporateCounsel.net Blog Published: 2023-02-24 06:48:47

rule filing with the SEC to implement the directive in SEC Rule 10D-1 to adopt a clawback policy, comply with that policy and provide the required clawback policy disclosures. ...
Down to the Wire: Your Clawback Questions Answered : TheCorporateCouns... Published: 2023-10-27 07:08:12

to adopt their exchange-compliant clawback policies is fast approaching. To catch up on the latest thinking on implementing clawback policies, be sure to mark your calendars ...
The SEC Clawbacks Compensation from Former Diebold CEO - But... Published: 2010-06-04 07:07:35

The SEC used the clawback provision under Section 304 of Sarbanes-Oxley to get the former ... "Clawback Policies" Practice Area) - but a ruling is expected soon... ...
SEC Open Meeting Next Wednesday: Final Clawback Rules on the... Published: 2022-10-20 07:34:37

about when reviewing and updating your clawback policy in light of recent enforcement ... more helpful info is available in our "Clawbacks" Practice Area on that site: - ...
Clawbacks: Do You Need to Check the New Form 10-K Checkbox? ... Published: 2023-12-14 07:06:38

This recent blog from Barnes & Thornburgh's Jay Knight has the skinny on some informal guidance from SEC Staff members who participated in AICPA and ABA conferences last week ...
Quick Survey: Clawback Policies : TheCorporateCounsel.net Blog Published: 2023-06-12 00:33:25

While companies may not need to rush out and adopt a new clawback policy over the summer, ... these considerations, we're also running a short, anonymous survey on clawback policies. ...
GT Alert_Clawbacks, Voluntary Disclosures, and Ephemeral Messaging... Published: 2023-03-08 12:28:16

& Special Investigations March 2023 Clawbacks, Voluntary Disclosures, and Ephemeral ... announced DOJ's practice of encouraging clawbacks (i.e., money already paid out must be ...
Your Summer Plans: A Dodd-Frank Clawback Policy : TheCorporateCounsel... Published: 2023-05-10 07:13:36

clawback policy requirements in detail: The SEC's recent designation of a longer period for taking action on proposed listing standards to implement Dodd-Frank clawback rules ...
View PDF Published: 2023-04-05 15:25:37

release clawback rule proposal On February 22, 2023, the NYSE and Nasdaq released their respective versions of a proposed rule that implements the SEC's clawback rule mandated ...
NYSE and Nasdaq Propose Compensation Clawback Listing Standards Published: 2023-04-05 15:22:06

NYSE and Nasdaq Propose Compensation Clawback Listing Standards Text Tracks Recently ... Market (Nasdaq) filed their proposed "clawback" listing standards with the SEC as ...
Hold-Through-Retirement and Clawbacks (CE November-December 2009... Published: 2025-01-19 12:04:31

The Corporate Executive, Vol. XXIII, No. 5 November-December 2009 Hold-Through-Retirement and Clawbacks Marc Trevino of Sullivan & Cromwell kicked off this panel by noting that a ...
SEC Obtains Another Clawback Without "Misconduct" : TheCorporateCounse... Published: 2011-11-18 06:31:57

he was still required under the clawback provision - Section 304 - of ... this action marked the SEC's third SOX clawback case against someone who was not alleged ...
A Broad Reach for Clawback Policies : TheCorporateCounsel.net... Published: 2023-01-30 06:48:19

extent to which a Rule 10D-1-compliant clawback policy could reach compensation in a ... Question 121H.04 Question: Because the clawback rule applies broadly to incentive-based ...
Now That's a Clawback: SOX Section 304 in Action : TheCorporateCounsel... Published: 2007-12-11 05:45:23

use by the SEC of the "clawback" provision under Section 304 of the Sarbanes-Oxley Act. ... For more on clawback provisions generally, take a look at our "Clawback Provisions" ...
Reg Flex Agenda: Clawback Re-Proposal Coming Next Year? : TheCorporate... Published: 2019-12-04 07:06:40

to see that clawbacks made the list! But pay-for-performance did not. The near-term agenda includes: 1. Auditor independence (April '20) 2. Clawbacks (September '20; this ...
Dodd-Frank Clawbacks: Nasdaq Extends Effective Date! : TheCorporateCou... Published: 2023-06-08 06:23:36

Following up on the NYSE amendment that I blogged about yesterday, Nasdaq has now also posted an amendment to its Dodd-Frank clawback listing standard proposal. Just like the NYSE ...
PUBLICATIONS FAQs on the SEC's Prescribed Clawback Policy Published: 2023-06-05 18:14:40

PUBLICATIONS FAQs on the SEC's Prescribed Clawback Policy June 1, 2023 Cam C. Hoang, ... requiring that listed issuers adopt clawback policies to recoup incentive-based ...
The Grasso Decision: Makes the Case for Clawbacks : TheCorporateCounse... Published: 2008-07-21 05:42:46

So what does this mean for you? It reminds us that a proper clawback can save a company ... of Compensation Standards to learn the "Ten Steps to a Clawback Provision with "Teeth." ...
Determining Named Executive Officers for Clawback Disclosure... Published: 2023-01-30 06:48:33

Under the SEC's new clawback disclosure rules, in a situation when a company completes the financial restatement that triggered the company's clawback policy, the company will be ...
Today's CompensationStandards.com Webcast: "SEC Clawback Rules... Published: 2022-12-15 07:10:15

Join us today at 2pm Eastern for the webcast, "SEC Clawback Rules: What To Do Now." We'll ... do to prepare for the SEC's new Dodd-Frank clawback rules that go into effect next month. ...
NYSE to Debt-only Issuers: You Need a Clawback Policy Too : TheCorpora... Published: 2024-02-07 00:05:35

a reminder to debt-only issuers that they, too, are required to adopt a clawback policy. ... Subsidiaries with listed securities should adopt a clawback policy to comply with the ...
NYSE Companies: Confirm Adoption of a Clawback Policy by December... Published: 2023-09-11 00:12:43

to listed issuers regarding the new clawbacks listing rules. After reminding companies that issuers must adopt a Dodd-Frank clawback policy no later than December 1st, NYSE ...
SEC Open Meeting Next Week: Re-Open "Clawbacks" Comment Period... Published: 2021-10-08 07:21:12

our agenda includes a panel covering "clawbacks" issues - the SEC issued this Sunshine ... to re-open the comment period for the clawback proposal that the Commission issued back ...
Wells Fargo: Directors Narrowly Re-Elected : Proxy Season Blog Published: 2017-04-26 06:22:00

Yesterday, Wells Fargo held its highly-anticipated annual meeting. It was rough despite the recent clawbacks. Here's a recap from this WSJ article by Emily Glazer: Wells Fargo's ...
Uncommon Item for a Directors Skills Matrix : Proxy Season Blog Published: 2020-02-27 06:03:00

I recently blogged on CompensationStandards.com about some shareholder proposals focused on tying clawback policies to reputational harm. But what surprised me the most about this ...