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'B' rla 6-29-10 Published: 2010-06-30 12:56:15... implement and disclose a "clawback" policy for recovery of incentive compensation. ... There is no deadline for the SEC to issue the required new and amended rules. Clawback ...
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S&C Publication: Key Considerations for Upcoming 2023 Form 10... Published: 2025-02-24 15:54:13... MJDS issuers are not subject to the new disclosure rules. Clawback Disclosures. Beginning ... fiscal year are required to file their clawback policies as exhibits and to indicate by ...
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A Broader Scope to the CD&A (But Only When Material) (CE July... Published: 2025-01-19 12:04:31... from employee actions in the short-term and long-term (for example, through clawback or holding period policies-see our November-December 2008 issue of The Corporate Executive ). ...
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(CE Sept-Oct 2012) Published: 2025-01-19 12:04:32... policy (as is the case with the yet-to-be proposed or adopted Dodd-Frank Act clawback provision), however it may be the case that defining "hedging" for the purposes of ...
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Supreme Court Ends SEC's Theory of "Implied Representation" ... Published: 2011-06-17 06:43:23... New Golden Parachute Requirement - The Latest SEC Actions: Compensation Advisors, Clawbacks, Pay Disparity & Pay-for-Performance - Dealing with the Complexities of Perks - ...
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A Little Debunking of the SEC's Records Destruction: "What is... Published: 2011-08-19 07:56:48... Options? - SEC Commissioners Reject Enforcement Staff Proposal to Settle Clawback Case - Clawbacks: Open Issues for the SEC - Senate Democrats Defend Pay Equity Disclosure ...
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IPOs: Are You Ready for Some (Fantasy) Football? : TheCorporateCounsel... Published: 2019-03-26 08:38:46... Fallout - The Top Compensation Consultants Speak - Navigating ISS & Glass Lewis - Clawbacks: #MeToo & More - Director Pay Disclosures - Proxy Disclosures: 20 Things You've ...
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Podcasts! Podcasts! Podcasts! : TheCorporateCounsel.net Blog Published: 2021-01-08 10:31:25... Mike cited 11 rules adopted by a 3-2 vote since July, which could be vulnerable to this clawback. In the year-end report on the activities of the Office of the Investor Advocate ...
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Cybersecurity Disclosure: SEC Enforcement Brings Fraud Charges... Published: 2023-10-31 07:48:37... And in a parallel to the new Dodd-Frank clawback rules, the SEC didn't like that he exercised options and sold SolarWinds stock during the time leading up to the announcement of ...
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Analysis: What Frequency for the Say-on-Pay Vote? : TheCorporateCounse... Published: 2010-11-09 07:02:07... and risk behavior, using an array of measures to mitigate such risk including clawbacks and stock-holding guidelines. - A number of non-financial companies retain ...
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XBRL: SEC Staff Provides First Guidance In Years : TheCorporateCounsel... Published: 2025-07-30 10:53:28... - In-House Perspective: Strategies for Effective Solicitations - Creating Effective Clawbacks (and Disclosures) - Pledging & Hedging Disclosures - The Executive Summary - The Art ...
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S&C Publication: 2025 Proxy Season ReviewPart 1 Published: 2025-08-15 15:54:42... 26 2. Low Support for Clawback Proposals ......- ESG 17▲ 15 7▼ 12 2%▼ 8% 0 ═ 0 Clawbacks 14▲ 12 10▲ 8 7%▼ 17% 0 ═ 0 Stock ...
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Timely Takes Podcast Published: 2025-01-22 09:36:37The SEC's priorities under Paul Atkins Glass Lewis 2025 updates ISS 2025 updates Nasdaq developments Recent staff clawback comments Listen Here: 1. Streaming Audio (for faster ...
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2010-CA-Dodd-Frank.indd Published: 2010-07-16 16:06:00... Q Revise Compensation Committee charter as necessary. Clawbacks Q Requires companies to ... Q Requires clawback of any portion of incentive compensation that would not have been ...
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US IPO Guide: 25 Edition Published: 2025-06-16 14:01:25... Incentive-Based Compensation Clawbacks ......FD policy, incentive-based compensation clawback policy, and identifcation of executive ...
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Microsoft Word - Client Alert - Inadvertent Document Production... Published: 2008-06-12 15:18:12possible and practical, enter into a clawback agreement with opposing counsel to ... Although they initially pursued entering into a "clawback agreement" with Plaintiffs - an ...
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US IPO Guide Published: 2024-06-17 14:53:53... Incentive-Based Compensation Clawbacks ......FD policy, incentive-based compensation clawback policy, and identification of executive ...
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Microsoft Word - 26May10FRB.doc Published: 2010-05-27 12:50:56... CEO. * Executive compensation clawbacks. Listed companies would be required to develop, implement and disclose policies with respect to the clawback of incentive- based ...
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1 Published: 2023-10-13 10:52:37... borrowing from a fund under management. 10. With respect to GP clawbacks, advisers may not reduce their clawback amounts by the hypothetical maximum tax payable (e.g., the ...
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Keeping the IPO Door Open What Every PE Portfolio Company... Published: 2023-01-17 13:29:18... Consider lead time to develop a clawback policy that will be required for all ... 16. Consider the impact of new "clawback" requirements The SEC has adopted rules ...
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The SEC recently proposed rules that will permit issuers to satisfy... Published: 2010-09-27 10:49:43... clawback policies and stock ownership and "hold til retirement" policies, should consider doing so. (As discussed below, companies will now be required to have clawback ...
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Navigating the Evolving SEC Regime for Foreign Private Issuers... Published: 2025-09-24 12:19:54rules adopted equally apply to FPIs and domestic issuers (such as the Rule on Clawback Policies, certain portions of the Rules on 10b5-1 Trading Plans and Insider Trading ...
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Crowdfunding: Should More Companies Be Going Public? : TheCorporateCou... Published: 2011-09-19 07:37:06... Here are some of the latest entries: - Internal Pay Disparity: Comments Coming In Ahead of SEC Proposals - Say-on-Pay Post-Mortems - An Analysis of Recently Adopted Clawback ...
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10-K & 10-Q Exhibits Handbook Published: 2025-08-13 11:11:13... Summary ...... 31-71 - Clawback Policy ......See Release No. 34-84509. Clawback Policy In October 2022, the SEC adopted fnal rules ...
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activePDF WebGrabber Published: 2009-01-30 20:41:21"unnecessary and excessive risks" that may impact the value of the institution, 2) clawback any bonus or incentive paid based on materially inaccurate earnings statements or ...
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Microsoft Word - EC Bulletin Hall et al article on Dodd-Frank... Published: 2010-07-01 13:46:54... Clawbacks Dodd-Frank requires public companies to establish policies to recover certain ... Both current and former executive officers are subject to this clawback. The legislation ...
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of Horribles (as sent to NYLJ).DOC Published: 2009-07-23 17:02:55of directors, executive compensation clawbacks, say-on-pay and independence ... This mandatory "clawback" obligation would require recovery or cancellation of such ...
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http://cecollect.com/ve/ZZ7680hCt68kijm891/stype=print Published: 2009-02-19 15:38:04... Expand the coverage of so-called "clawback" provisions-which allow the TARP ... SEOs No substantive change from Stabilization Act Clawback of bonus, retention award or ...
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Edition Published: 2017-10-19 14:17:31... ✓ Maintained Executive Compensation Clawback Policy ✓ No Accelerated Stock Vesting ... . . . . . . . . . . . . . . . . . . 42 "Clawback" Policy Regarding the Adjustment or ...
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http://www.akingump.com/communicationcenter/newsalertdetail.asp Published: 2010-07-16 16:12:20... The Act does not set a deadline for SEC implementation of this provision. Clawbacks Effectively requires issuers to develop and disclose clawback policies for the recovery of ...
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PROXY ADVISOR POLICY CHANGES FOR 2015 By Shirley Westcott December... Published: 2014-12-02 19:24:48Glass Lewis has also enhanced its guidelines pertaining to say-on-pay (SOP) proposals (clawback policies and one-off awards to executive officers) and to employee stock purchase ...
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Joint Meeting of CAQ SEC Regulations Committee & SEC Staff Published: 2025-06-02 15:57:21... III. CURRENT FINANCIAL REPORTING MATTERS A. Clawback Rule Checkboxes Pursuant to the SEC's final clawback rules, the cover pages of annual reports (Forms 10-K, 20-F, and 40-F) ...
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Your 2025 Form 10-K Roadmap Published: 2025-11-21 17:19:04... Clawback rule guidance The SEC adopted final rules in October 2022 that directed U.S. ... requiring all listed companies to adopt and comply with a written clawback policy. ...
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SUSTAINABILITY AND BEYOND. Published: 2021-12-17 11:02:33... comment period for its proposed 2015 clawback rule, the SEC has, among other things, ... will need to attempt a clawback or disclose why attempting a recovery is not feasible. ...
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New Executive Compensation Corporate Governance Rules Proposed Published: 2010-03-22 15:09:33... Clawback Policy Required Exchange-listed issuers are required to develop and implement a policy providing (A) for disclosure of the issuer's policy on incentive-based compensation ...
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http://www.proskauer.com/publications/client-alert/the-impact... Published: 2010-07-26 19:16:55... Clawbacks - Recovery of Incentive-Based Compensation Under rules to be promulgated by the ... The SEC will also issue rules addressing the disclosure of a company's clawback policy. ...
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Proxypulse-MidSeason-2015-Web_4bs.indd Published: 2015-07-09 14:28:14In addition, new, more extensive clawback rules are expected in the short-term. At 30% of street shares, retail share ownership increased slightly from the same period last year. ...
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Microsoft Word - 5637221_5.DOC Published: 2010-05-27 12:09:45and other advisors. * Clawback of "Erroneously Awarded" Compensation. Listing exchanges will also be required to adopt new rules providing for the clawback of incentive ...
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Copyright © 2024 Wilson Sonsini ... Published: 2024-12-13 12:08:06... Clawback Policy and Disclosure Updates. As discussed in last year's reporting season Alert, companies were required to comply with the clawback disclosure rules, including filing ...
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clearygottlieb.com Published: 2023-12-23 11:34:29... These changes include: (A) cybersecurity disclosure, (B) compensation recovery ("clawback"... related to compensation recovery, or "clawback," disclosure. 7 The clawback rules apply ...
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2022-2023 YEAR-END TOOL KIT Published: 2023-01-04 10:11:31... meetings The SEC rules on compensation "clawbacks," including new stock exchange listing ... UPDATES AND REMINDERS SEC Adopts Final Clawback Rules In October 2022, the SEC adopted ...
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Could Your Incentive Plan be Subject to ERISA? (CE May-June 2017... Published: 2025-01-19 12:04:34... If deferral is essential to the purposes of the incentive plan, e.g., to facilitate the retention of employees or the company's ability to clawback award amounts, limit the amount ...
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PWC's Annual Study Shows Jump in Litigation : TheCorporateCounsel... Published: 2025-07-31 21:05:26... should be evaluated over time to avoid excessive risk taking and to allow for a clawback effect. 5. Equity awards should be subject to future delivery and/or deferred ...
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ISS: New Draft Approaches to Equity Plan & Independent Board... Published: 2014-10-16 08:14:07... (as opposed to strictly time-based vesting), whether the company maintains a clawback policy, and whether the company has established post-exercise/vesting holding requirements. ...
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Timely Takes Published: 2025-01-19 12:36:145th Circuit Panel's Decision Upholding Nasdaq's Board Diversity Disclosure Rules NYSE Clawback Policy Affirmation Requirement Listen Here: 1. Streaming Audio (for faster play) 2. ...
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CBCA Amendments Codify Best Interests... Published: 2019-07-05 11:22:59minorities - each as defined by the federal Employment Equity Act), compensation clawback mechanisms and the well-being of employees, retirees and pensioners (see our April ...
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NEW YORK Published: 2023-11-17 12:00:13... in connection with termination without cause. 4. Clawbacks ISS None Glass Lewis Glass Lewis polled respondents on whether clawbacks should be applied under various scenarios. ...
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View PDF Published: 2022-09-19 15:10:02self-disclosures, independent compliance monitors, off-systems communications and the promotion of compliance through financial incentives, including compensation clawbacks. ...
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Annual Corporate Governance Review Published: 2018-11-19 12:52:12... 30.7% 68.8% 0.5% 24.2% 56.0% 0.4% 9.9% > Clawback of Incentive Payments 7 39.4% 59.2% 1.4% ... AmerisourceBergen Corporation (Holding Co) Executive Compensation - Clawback of Incentive ...
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Resources Published: 2010-08-28 21:37:46... Clawbacks The Act mandates that the SEC establish rules requiring national securities exchanges to require that listed companies implement an executive compensation clawback ...
