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The Latham FPI Guide: Accessing the US Capital Markets From Outside... Published: 2018-09-11 16:49:03... Proposed Incentive-Based Compensation Clawbacks Under Dodd-Frank ......Proposed Incentive-Based Compensation Clawbacks Under Dodd-Frank Under Dodd-Frank ...
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The Latham FPI Guide: Accessing the US Capital Markets From Outside... Published: 2019-09-10 16:21:51... Proposed Incentive-Based Compensation Clawbacks Under Dodd-Frank ......Proposed Incentive-Based Compensation Clawbacks Under Dodd-Frank Under Dodd-Frank ...
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Global and Regional Trends Published: 2017-01-12 12:53:32... Given investor pressure, particularly from pension funds, we also anticipate increased demand for clawbacks, a trend that is likely to go beyond the banking sector. ɳ We expect ...
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_ Published: 2025-02-21 11:23:12... policies and practices with regard to compensation clawbacks; and pay versus performance. ... In connection with adoption of the clawback disclosure requirements of Item 402(w), ...
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© 2025 Pillsbury Winthrop Shaw ... Published: 2025-04-07 11:31:14... pivot toward more stringent deal terms for awardees-potentially including tougher compliance obligations, enhanced clawback provisions or stronger domestic job creation guarantees. ...
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DODD-FRANK Preliminary 2014 Proxy Season Checklist Published: 2013-09-30 13:53:42... in 2014. 3. Clawback requirements (Section 954 of the Dodd-FrankAct) Disclosure of policy on incentive-based compensation based on financial information Clawback in the ...
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739133_007_BMK.PDF Published: 2014-08-07 23:35:15... compensation recoupment (so-called "clawback") provisions, and disclosure of internal ... companies to develop and implement "clawback" or compensation recovery policies with ...
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WSGR Alert Senate Set to Debate Financial Reform Bill Corporate... Published: 2010-03-29 20:41:34... D. Clawback Policy Both the previous bill and Section 954 of the current bill would ... of companies that do not adopt a clawback policy for incentive- based compensation ...
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Checklist: Restatements By TheCorporateCounsel.net Published: 2023-06-07 10:18:05... to be able to file Jumbo Form 10-K. 8. Potential Subsequent Ramifications a. Clawbacks: i. ... Many companies have voluntarily adopted clawback policies covering both cash and equity ...
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C:\DOCUME~1\ayo\LOCALS~1\Temp\\REGMODII.lc Published: 2009-11-10 12:03:04... Sec. 954. Executive compensation disclosures. Sec. 955. Clawback. Sec. 956. Disclosure ... SEC. 955. CLAWBACK. 9 Section 16 of the Securities Exchange Act of 1934 10 (15 U.S.C. 78p) ...
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STRAIGHT TALK IS GOOD BUSINESS. Published: 2014-11-18 19:00:26... conditions; (5) whether the issuer has a clawback policy; and (6) whether the issuer has ... favorable to the issuer (for example, a clawback policy if an issuer will seek ...
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2016 Proxy Season Preview Published: 2016-03-01 18:02:54... Several other anticipated disclosure rules are not yet finalized, including those related to executive pay-versus-performance, clawbacks of incentive-based executive compensation, ...
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Annual Meeting Guidebook A Guide to Broadridge's Corporate Issuer... Published: 2020-03-06 14:40:59... filing for the quarter. * There has been talk of listing standards for clawbacks of compensation to adopt the SEC's 2015 proposal to implement Section 954 of the Dodd-Frank Act. ...
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Selected Issues for Boards of Directors in 2020 Published: 2020-01-13 13:36:41... 0 2 0 JA N UA RY 2 0 2 0 8 Compensation Clawbacks and Advancement of Legal Fees A ... Hertz Corporation sought a clawback of the compensation of executives (and sought other ...
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Microsoft Word - 3-19-10 Corporate Governance Group Client Alert... Published: 2010-03-19 21:46:40... disclosure could include a graphic representation of the required information. Clawbacks. ... The amount of an officer's clawback obligation would be the amount in excess of what would ...
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30 directors & boards Published: 2012-04-13 21:16:36... Dodd-Frank implementation 9% Mandatory clawbacks 9% independent board chair 4% advisory ... Dodd-Frank implementation 7% Mandatory clawbacks 4% advisory votes on golden parachutes ...
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EXEQUITY Published: 2009-12-17 18:25:47... Some factors that could potentially mitigate the impact of risk incentives are rigorous clawback provisions and robust stock ownership/holding guidelines. If a company maintains a ...
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2017 NORTH AMERICA AGM SEASON PREVIEW Published: 2017-03-27 16:23:33... The long- awaited final rule on Dodd Frank clawback provisions is notable among those in limbo. APPENDIX The Proxy Season Preview Webinar accompanying this document may be found at ...
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Preliminary 2011 Proxy Season Checklist Published: 2010-10-26 12:30:35... July 2011 4. Clawback requirements (Section 954 of the Dodd-Frank Act) -Disclosure of policy on incentive-based compensation based on financial information -Clawback in the event ...
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Investment Management Material Investment Management Developments... Published: 2022-05-05 10:37:38... of general partner or limited partner clawbacks. * Removal of a private fund's general ... the amount of the private fund adviser's clawback by the amount of taxes (actual, ...
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S&C Publication: 2024 Hot Topics for Boards and Committees Published: 2024-09-12 11:34:22... -5- 2024 Hot Topics for Boards and Committees Reassessing Clawback Policies - After the NYSE and Nasdaq clawback rules requiring listed companies to mandate recoupment of ...
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PUBLICATIONS DOJ to Develop New Whistleblower Program to Augment Published: 2024-03-15 10:37:40... fully with the government,[5] establish clawbacks of compensation given to individual ... Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance ...
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1486429-2023 GIC-GAAP-non-GAAP PDF+Web Graphics Published: 2024-03-20 10:35:57... required disclosures on pay for performance, cyber risk governance and clawback policies. ... Similarly, investors will be examining how companies respond to the clawback rules that ...
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Federal Trade Commission Issues Sweeping Non-Compete Ban Published: 2024-04-25 11:54:16... The rule also takes aim at forfeiture-for-competition provisions, including those requiring or permitting the forfeiture or repurchase of equity interests or the clawback of ...
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Compliance Dates Are Set: A Roadmap for Private Fund Advisers... Published: 2023-10-06 10:32:10... regulatory, examination, or compliance fees without disclosure; and (iv) reducing GP clawbacks of fees from advisers by amounts due for certain taxes without adequate disclosure. ...
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In depth US2014-01 Revenue recognition Asset management supplement Published: 2014-09-26 14:53:41... fees that are based on current assets under management and are not subject to clawback. ... from a fund exceed the clawback portion of the historic performance fees distributions. ...
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TEN HOT TOPICS Published: 2018-07-03 15:37:58... on equity award vesting * 6 proposals on clawbacks * 22 proposals on using particular performance metrics * 12 proposals on clawbacks * 8 proposals on equity award vesting ...
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Weil, Gotshal & Manges LLP Published: 2014-11-12 19:03:20... l ¡ Whether the company maintains a clawback policy l ¡ Whether the company has ... Consideration of One-Off Awards and Clawback Policies - NEW Glass Lewis has added a ...
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Davies Governance Insights 2015 Published: 2015-11-17 21:08:01... 73% 72% 82% 81% 74% 2015 2014 2013 2011 TSX 60 Completion Index SmallCap Index CLAWBACKS Clawback provisions require CEOs to either repay some or all of their bonuses or ...
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http://www.foleyhoag.com/NewsCenter/Publications/Alerts/Busines Published: 2009-03-05 01:53:40... Your company's incentive plans may have their own separate clawback provisions. At a minimum, your compensation committee may have a problem on its hands. Incorrect financial ...
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Copyright © 2022 Wilson Sonsini ... Published: 2022-12-15 16:07:08... Compensation Recoupment ("Clawback") Provisions Glass Lewis updated its guidance on ... listing standards to implement the new clawback policy rules, after which listed ...
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Faster, Stronger, Better. Published: 2021-11-08 11:25:39... our programs that include a stringent clawback policy, rigorous stock ownership ... or pledging Company stock * Stringent clawback policy applicable to directors and ...
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01959-HC ERP74_v3.indd Published: 2008-12-01 20:36:36... Proposals that saw some action in 2008 included "say on pay," a ban on tax gross-ups, clawback provisions, and internal pay equity policies. Review governance policies. It may be ...
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Plan Scorecard Frequently Asked Questions Published: 2025-04-02 10:48:58... practice, particularly for large cap, mature companies. › A clawback policy that includes equity grants - clawback policies are seen as potentially mitigating excessive ...
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ExecComp_Update_021609.qxp Published: 2009-02-17 15:59:44... Clawback of Bonuses for Deceptive Practices The Act contemplates the recovery of any ... this provision would apparently permit a clawback even where the affected employee had no ...
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http://www.simpsonthacher.com/newsletter/index.cfm?itemId=F9510 Published: 2009-02-20 12:05:13... Clawback on Bonuses Paid to "Top 25" based on Materially Inaccurate Financial Statements. ... that the employees subject to this clawback provision be responsible for the inaccuracy). ...
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W&C Standard Template Published: 2018-02-21 14:16:10... Expanded Clawback In addition to supporting shareholder proposals for clawbacks from any senior executive whose compensation was based on faulty financial reporting or deceptive ...
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Microsoft Word - 9179_WeilBriefing_CG_2009-12-14.doc Published: 2009-12-15 11:28:21... such other period determined by the SEC. 18 Clawbacks of Unearned Performance-Based Pay. ... than the existing incentive compensation clawback provided by Section 304 of the Sarbanes- ...
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OFFICE OF THE NEW YORK CITY COMPTROLLER SCOTT M. STRINGER | 1 Published: 2020-12-02 18:22:33... The letter called on the board to enact a clawback policy to empower the board to recoup ... Opioid-Related Risks at Johnson and Johnson Executive Compensation Clawback Disclosure ...
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Deconstructing Proxy Statements - What Matters to Investors Published: 2015-02-17 15:30:34... pay 28 Board evaluation process 28 Clawbacks 24 Corporate social responsibility or ... profile 10 Board evaluation process 10 Clawbacks 7 Realized/realizable pay 5 Ratio of ...
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Inside back cover Published: 2015-12-18 11:09:34... in accordance with SEC rules (commonly known as "clawback of executive compensation"). ... Additionally, companies may wish to add a reference to establishing clawback policies to ...
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Empirical Research on ESG Factors and Engaged Ownership Published: 2021-12-03 10:25:34...0and%20Mullainathan_2001_Elites.pdf. 25. Clawback provisions enabling the recoupment of ... Chan, L., Chen, K. C. W., Chen, T. and Yu, Y. 2011. The Effects of Firm-Initiated Clawback ...
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7175502_1.DOC Published: 2009-01-16 12:25:15... Previously, RiskMetrics did not support shareholder proposals on "clawbacks" of incentive ... Both of these policy positions, as well as RiskMetrics' "best practices" for clawbacks, ...
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Blank Published: 2017-01-13 17:40:50... CFO Clawbacks In a significant legal development for the Division of Enforcement, a federal court of appeals recently affirmed the authority of the SEC to obtain clawbacks of ...
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Hunton & Williams Corporate and Securities Law Update: Executive... Published: 2010-07-20 19:55:31... Certain Enforcement Reforms Incentive Compensation Clawbacks Section 954 of Dodd-Frank ... The Dodd-Frank clawback requirement goes beyond the similar provision in the ...
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The Bribery Offenses Published: 2010-12-23 12:12:01... Clawbacks The Act requires that companies implement policies permitting the clawback of incentive compensation erroneously paid to company executives as a result of material ...
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WSGR Alert Published: 2025-01-06 14:39:26... "robust" clawback policy in the "Executive Compensation Analysis" section of its company research reports for purposes of say-on-pay vote evaluations, a company's clawback policy ...
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Date Published: 2014-11-17 11:49:45... on Executive Compensation: One-Off Awards, Employee Stock Purchase Plans, and Clawbacks. ... In addition, Glass Lewis advises that clawback policies should be (i) triggered upon a ...
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Brian V. Breheny Published: 2014-11-12 17:57:14... conditions; whether the company has a clawback policy; and whether the company has ... tices" analysis. * For a company with no clawback or share holding period requirements, ...
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The Emergency Economic Stabilization Act of 2008 Published: 2008-10-06 11:40:37... that encourage unnecessary risk-taking, clawback of bonuses or incentive compensation ... Notably, the standards for clawbacks and golden parachute payments only apply to "senior ...