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Compensation Committee Guide Published: 2025-10-28 00:08:07

... CHAPTER X. Compensation Clawback Rules ......C. Considerations for Adopting Clawback Policies ......116 D. ...
CScom-TCC_Course Materials_Your Upcoming Proxy Disclosures_0125... Published: 2025-07-29 19:12:33

Potential Impact on Compensation Disclosure 3. Evolution of Clawback Policies 4. Pay vs. ... and advisors 3. Evolution of Dodd-Frank Clawback Policies under Exchange Act Rule 10D-1, ...
Proposed Incentive-Based Compensation Rule Under Dodd-Frank Act... Published: 2025-01-19 12:04:33

... substantive and procedural criteria for forfeiture and clawback Document final forfeiture, downward adjustment, and clawback decisions Specify the substantive and procedural ...
PDEC Conferences: Join Us in Las Vegas! : TheCorporateCounsel... Published: 2025-05-21 14:11:16

Environment," "Delaware Hot Topics: Navigating Case Law & Statutory Developments," "The Proxy Process: Shareholder Proposals & Director Nominations" and "The Year of the Clawback." ...
Proxy Disclosure & 20th Annual Executive Compensation Conferences... Published: 2023-03-22 07:32:40

Consultants Speak 16. Pay Versus Performance: What's New for Year Two 17. Clawbacks: Key Action Items Now 18. ESG Metrics: Beyond the Basics 19. Navigating ISS & Glass ...
T-minus One Week: Register for Our Conferences Today! : TheCorporateCo... Published: 2023-09-12 06:10:20

A wide range of panelists will address hot topics in executive compensation today - from ESG metrics to clawbacks. Here's the full agenda - and all of our experienced speakers. It ...
Microsoft Word - 19 July 2010 Dodd Frank Executive Compensation... Published: 2010-07-20 20:03:28

and internal pay equity  mandatory "clawback" policies applicable to all current and ... This process for many companies will be complicated and time-consuming. Clawbacks Clawback ...
SHAREHOLDER INITIATIVES PROXY PAPER Published: 2015-01-29 19:15:50

... Recoupment Provisions ("Clawbacks") ......RECOUPMENT PROVISIONS ("CLAWBACKS") We believe it is prudent for boards to adopt detailed ...
Debevoise Update D&P Published: 2024-12-24 08:45:33

The deterrent effect of the potential for forfeiture or clawback should provide many ... the company sought to recover, via a clawback mechanism, eight years' worth of sales ...
Senate Passes Financial Regulatory Reform Bill Impacting Corporate... Published: 2010-05-27 12:53:38

committee and adviser independence and clawbacks, and other disclosure matters. ... Compensation Clawbacks Under the Senate bill, the SEC must issue rules directing national ...
Glass Lewis 2024 Policy Revisions Published: 2023-12-27 22:53:33

executive ownership guidelines, clawback provisions, board oversight of ... Clawback Provisions Glass Lewis has updated its policy on clawback provisions in light of ...
Securities Advisory Preparation for 2015 Fiscal Year-End SEC... Published: 2016-02-02 12:08:49

pay for performance in April, and clawback of "erroneously awarded compensation" in ... such as executive compensation clawbacks, stock ownership guidelines, and ...
Rose K. Alappat Laura María Lintner J. Sue Morgan Patrick (Pat... Published: 2010-07-22 11:25:38

and internal pay ratio; mandatory clawback of some incentive compensation; ... Practical Tip Mandatory Clawbacks. Companies listed on national securities exchanges must ...
SEC Adopts Amendments to Form PF; Establishes Certain EventReporting... Published: 2023-05-17 10:54:53

including regarding GP or certain LP clawbacks, and also amend four existing questions, ... * General Partner or Limited Partner Clawback (Section 4, Question 82): This new ...
Proxy Statements: Pru Includes Lead Director Video : TheCorporateCouns... Published: 2015-03-27 06:55:09

independent third party - Box on board engagement that highlights the adoption of a clawback and proxy access through engagement efforts - Boxes on environmental & sustainability ...
Reg Flex Agenda: The New-Fangled One Is Here! : TheCorporateCounsel... Published: 2017-12-18 11:39:57

include those proposals that the SEC isn't likely to tackle in the near term. That includes leftover Dodd-Frank rulemakings like pay-for-performance, clawbacks and hedging. ...
Dissecting the SEC's Enforcement Numbers - and Its Fines : TheCorporat... Published: 2009-08-05 06:57:18

GE's "disclosure of perks" settlement with the SEC in '04). Note the third in the trio is the CSK Auto clawback action. These cases follow SEC Chair Schapiro's comments back in ...
Pay Ratio - Year 2: Sample "Median Employee" Disclosures : TheCorporat... Published: 2019-03-13 08:51:20

of Pay Governance discuss these topics: - Second year of pay ratio - Evolution of clawbacks - Adjustments to incentive plan actual performance or goals & goal-setting plans - ...
Must Public Companies Have a "Principal Accounting Officer"?... Published: 2024-11-14 07:02:26

and NYSE rules also don't explicitly require companies to have a PAO and treat the controller as the PAO and an executive officer for purposes of the clawback listing standards. ...
TheCorporateCounsel.net's Published: 2025-09-18 10:48:02

......... 2-54 - Clawback-Related Actions ......Clawback-Related Actions The company must indicate whether its fnancial statements ...
SHAREHOLDER INITIATIVES PROXY PAPER Published: 2015-11-29 20:47:28

... 12 Recoupment Provisions ("Clawbacks") ......RECOUPMENT PROVISIONS ("CLAWBACKS") We believe it is prudent for boards to adopt detailed ...
SEC Reporting Update: Highlights of trends in 2024 SEC staff... Published: 2024-10-23 08:35:12

requirements) and recently adopted SEC disclosure rules on cybersecurity and clawbacks. ... The SEC staff has said that it will continue to focus on clawback disclosures, including ...
2025 Benchmark Policy Guidelines Published: 2025-09-09 11:23:12

... Adopt or Amend Recoupment Provisions (Clawbacks) ......Adopt or Amend Recoupment Provisions (Clawbacks) Section 954 of the Dodd-Frank Act ...
ESG Initiatives Published: 2021-11-18 11:48:19

... Adopt or Amend Recoupment Provisions (Clawbacks) ......Adopt or Amend Recoupment Provisions (Clawbacks) Section 954 of the Dodd-Frank Act ...
ESG Initiatives Published: 2022-12-07 10:31:58

... Adopt or Amend Recoupment Provisions (Clawbacks) ......Adopt or Amend Recoupment Provisions (Clawbacks) Section 954 of the Dodd-Frank Act ...
2024 Benchmark Policy Guidelines Published: 2024-11-19 10:02:39

... Adopt or Amend Recoupment Provisions (Clawbacks) ......Adopt or Amend Recoupment Provisions (Clawbacks) Section 954 of the Dodd-Frank Act ...
Season: Key Issues and Considerations Published: 2023-12-20 17:29:32

COMPENSATION MATTERS - Dodd-Frank Clawback Regulation (Stefan P. Smith, Janet A. ... Compensation Matters Dodd-Frank Clawback Regulation (Authors: Stefan P. Smith, ...
White Collar: Year in Review and a Look Forward, 20232024 Published: 2024-01-08 16:00:43

Clawback Pilot Program Launched In the spring, Deputy Attorney General Lisa Monaco announced the launch of a significant pilot program on compensation incentives and clawbacks ...
Need to Know for 2025: Top 10 Tips for the Form 10-K Published: 2025-01-06 10:00:01

of those error corrections required a clawback recovery analysis 2. Part I, Item 1. ... Boxes for Financial Restatements and Clawback Analysis  Form 10-K includes two ...
Should You Make Your Executive Severance Plan Subject to ERISA... Published: 2025-01-19 12:04:34

... Clawbacks. A severance plan document, including a plan subject to ERISA, can incorporate clawback provisions that would allow the employer to halt or even recover severance ...
An Example of Revisiting Employment Agreements : TheCorporateCounsel... Published: 2004-09-27 05:39:06

re-examine, modify existing arrangements - Fixing and adding "cause" provisions and clawbacks - Ways to address current excessive compensation and how to have a difficult ...
Rumor! SEC to Propose Pay Disparity Rules Soon : TheCorporateCounsel... Published: 2013-07-18 08:34:47

for Effective Solicitations - The SEC Staff Review Process - Creating Effective Clawbacks (and Disclosures) - Pledging & Hedging Disclosures - The Executive Summary - The Art ...
Coming Soon(ish): SEC's "Semi-Annual Reporting" Proposal : TheCorporat... Published: 2025-07-31 16:20:09

And these open rulemakings remain on the 'long-term' burner: clawbacks; pay-for-performance; conflict minerals; universal proxy; board diversity disclosures; proxy plumbing - and a ...
XBRL: Corp Fin Posts Sample Comment Letter : TheCorporateCounsel... Published: 2023-09-08 10:16:05

In addition, new XBRL requirements have accompanied several recent SEC rulemakings (clawbacks, pay vs. performance, repurchases, insider trading), so there actually are new ...
Giving Thanks 2023: My Thanksgiving Reflections : TheCorporateCounsel... Published: 2023-11-22 07:54:52

More on those to come. 2. We are almost at the clawback policy finish line. Next Friday is the deadline for companies to adopt a clawback policy that complies with exchange listing ...
More Fake News: Twitter's "Unreal" Tender Offer : TheCorporateCounsel... Published: 2015-07-15 09:20:06

Please print these "Course Materials" in advance... Don't forget to tune into today's CompensationStandards.com webcast - "Clawbacks: What Now After the SEC's Proposal" - to hear ...
SEC Pushes Back Dates for Executive Compensation & Other Rulemakings... Published: 2011-08-02 07:11:18

broker voting of uninstructed shares Thus, it seems unlikely that all five of the clawback, pay-for-performance, CEO pay ratio, incentive compensation rules for large financial ...
Transcript: "The Latest: Your Upcoming Proxy Disclosures" : TheCorpora... Published: 2025-02-05 07:22:52

I'm less concerned about the other two rules, pay versus performance and the clawback ... As for the clawback rule, we're just beginning to see the scope and implications of the ...
SHAREHOLDER INITIATIVES Published: 2018-10-30 16:44:43

... Adopt or Amend Recoupment Provisions ("Clawbacks") ......RECOUPMENT PROVISIONS ("CLAWBACKS") We have revised our policy concerning proposals ...
XPP-PDF Support Utility Published: 2010-07-20 19:59:57

... The clawback covers all current and former executive officers and is triggered by a ... SEC filing is made. 5. Clawback Policies s Listing Standards Regarding Clawbacks. ...
Preparing Your 2015 Form 20-F Published: 2015-12-17 12:29:49

... Dodd-Frank Clawback Rule On July 1, 2015, the SEC proposed a rule implementing Section 954 of the Dodd-Frank Act, which requires listed companies to implement clawback policies to ...
Corporate_Dodd-FrankProvisions_July 27 2010.doc Published: 2010-07-30 12:53:18

of financial statements triggers a "clawback", brokers' ability to vote shares for ... Compensation "Clawback" Provisions Section 954 of Dodd-Frank requires that the SEC adopt ...
SEC Adopts Amendments to Rules Governing Rule 10b5-1 Trading... Published: 2023-06-27 14:23:19

reporting events, such as an extraordinary investment loss or limited partner clawback. ... o General Partner and Limited Partner Clawbacks - New Question 82 has been added to ...
Financial Reform Act Brings Significant Executive Compensation... Published: 2010-07-16 16:14:52

to compensatory matters generally. 2 Clawback Policies National securities exchanges ... Issuers must also disclose their clawback policies. The Reform Act does not specify an ...
A "Wow": Corp Fin Allows Exclusion of Golden Parachute Shareholder... Published: 2010-12-16 07:20:29

The CEO Dan Ustain that presided over this alleged fraud was the subject of a relatively rare Section 304 clawback action from the SEC - but he still runs the company (see this ...
More Coming Attractions: Acting SEC Chair Highlights Regulatory... Published: 2025-02-24 21:21:52

new rules, including cybersecurity disclosure, the Rule 10b5-1 amendments, and the clawback rules, and has provided only limited relief to EGCs for its climate disclosure rules. ...
SEC Issues New Pay Ratio Analysis (& Our 20% "Executive Pay Conference... Published: 2015-06-05 12:11:32

The SEC's new pay-for-performance & hedging proposals - not to mention the coming clawback ... What to Do Now - Creating Effective Clawbacks (& Disclosures) - Pledging & Hedging ...
Current Developments in SEC Enforcement for Public Companies... Published: 2024-03-21 16:57:32

and transactions  Section 304(a) clawbacks  Self-reporting and cooperation  ... Lewis 12 www.morganlewis.com SOX 304 Clawbacks Aggressive Approach to Clawbacks of ...
Securities Advisory Preparation for 2014 Fiscal Year-End SEC... Published: 2015-02-03 15:15:26

such as executive compensation clawbacks, stock ownership guidelines, and ... A clawback policy that includes equity grants - Clawback policies are seen as potentially ...
Current Developments in SEC Enforcement for Public Companies Published: 2023-06-06 14:29:37

 Insider trading  SOX 304 clawbacks  Cryptoassets  Regulation FD  ... terms of each such plan. 53 SOX 304 Clawbacks Aggressive Approach to Clawbacks of ...