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Results from: TheCorporateCounsel.net
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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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http://akingumpinfo.com/ve/ZZm80S91W74Cb7978Q/stype=print Published: 2008-12-05 11:23:13... In addition, RiskMetrics has updated its burn rate percentages. RiskMetrics may now support shareholder proposals for "clawbacks" of incentive pay if existing company policies do ...
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NY3 - 501026.03 Published: 2010-01-07 18:57:08... NY3 - 501026.033 RiskMetrics will also consider factors that mitigate the impact of risky incentives, such as "rigorous" clawbacks and "robust" stock ownership/holding guidelines. ...
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Compensia Published: 2009-12-11 13:35:31... It will also consider the extent to which program features such as clawback policies or stock ownership and holding requirements may mitigate risk. While the novelty of the issue ...
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On the boards agenda: August 2016 Published: 2016-08-02 13:15:14... seeking the adoption or disclosure of clawback policies may also have diminished due to the SEC's proposal of clawback rules-even though those rules have not yet been adopted. ...
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INVESTMENT BANKING Published: 2009-04-10 09:21:00... including no full vesting while TARP assistance remains outstanding - Bonus "clawback" provisions upon material misstatements now apply not just to top five senior ...
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Corporate Governance and Executive Compensation Provisions in... Published: 2010-08-04 23:48:23... Clawback Policy Dodd-Frank mandates exchanges to adopt listing standards requiring that listed companies develop and implement a clawback policy for accounting restatements. The ...
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Proxy Advisory Firms Issue 2019 Voting Guidelines Published: 2018-11-29 18:58:37... use. * Revising the policy on clawback provisions to focus on their specific terms rather than on whether the clawback satisfies minimum legal requirements under Sarbanes-Oxley. ...
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SHAREHOLDER PROPOSAL DEVELOPMENTS DURING THE 2024 PROXY SEASON Published: 2024-07-30 09:49:13... goals; (iii) compensation clawback policies; (iv) equity award vesting; (v) ... submitted in 2022. 6 amendments to clawback policies for incentive compensation ...
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Department of Justice Announces ... Published: 2024-03-12 09:48:07... In March 2023, DOJ launched a Pilot Program on Compensation Initiatives and Clawbacks. That initiative calls for reduced criminal fines for certain companies that make good faith ...
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ISS and Glass Lewis Update Their Proxy Voting Guidelines for... Published: 2016-11-30 16:54:40... subject to performance conditions; * Whether the company maintains a clawback policy; and/or * Whether the company has established post-exercise/vesting shareholding requirements. ...
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Securities Law Alert Author(s): Kelly... Published: 2017-11-20 19:51:19... disclosure, compensation clawbacks and director and employee hedging ... advisory vote requirements, proposed clawback requirements, mine safety disclosures, ...
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PLI Current The Journal of PLI Press Published: 2018-08-27 18:41:43... In addition, highlight mitigating factors in the company's executive compensation program, including clawbacks, holding requirements, prohibitions on hedging or pledging, and ...
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Governance Changes Under Dodd-Frank: What to Do and When Published: 2010-09-17 19:59:10... in connection with extraordinary corporate transactions, heightened inde- pendence requirements for compensation committee members and advisors, and clawback policy requirements. ...
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Local: X:\Users\HEWETTCA\Desktop\1_22_16_Governance alert.docx Published: 2016-01-26 19:13:57... proposing the incentive compensation "clawback" rule, the pay-for-performance ... Clawback Rule The Dodd-Frank rulemaking that likely will attract the most interest in the ...
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3207 BSL Mar.qxd Published: 2004-05-17 15:26:26... Unlike traditional private funds, there is typically no "hurdle rate" relating to realized capital gains and there is no clawback or high- water mark in connection with these ...
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J. Sue Morgan Jens M. Fischer Andrew B. Moore Danielle Benderly Published: 2009-12-23 17:51:47... or balance incentives, such as clawback policies or stock ownership/holding requirements. ... In addition, companies may want to consider implementing "clawback" or "stock ownership/...
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ISS Published: 2012-01-22 19:43:31... Jan.-June 2012) - Final (Est. July-Dec. 2012) * Pay for Performance * Clawbacks - Could your company enforce recapture? * Hedging Policy Disclosure * Pay Disparity - Repeal? * ...
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Selected Issues for Boards of Directors in 2017 Published: 2017-01-17 18:50:37... SELECTED ISSUES FOR BOARDS OF DIRECTORS IN 2017 JANUARY 17, 2017 20 Compensation Considerations Clawbacks The potential clawback of executive compensation, an area of focus for ...
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View PDF Published: 2023-09-22 11:57:39... Notably, the SEC has recently adopted a proscriptive clawback rule that applies to foreign private issuers and their executive officers and a rule mandating quarterly disclosure of ...
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Debevoise Update D&P Published: 2023-08-16 16:21:11... in May 2021 and June 2021 demanding a return of capital to shareholders and a clawback of certain directors' pay; Finland-based Sampo Group, which divested its stake in ...
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The Latham FPI Guide: Accessing the US Capital Markets From Outside... Published: 2017-09-21 16:53:46... Proposed Incentive-Based Compensation Clawbacks Under Dodd-Frank ......Proposed Incentive-Based Compensation Clawbacks Under Dodd-Frank Under Dodd-Frank (adding ...
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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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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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Fraud Section - Year in Review - January 2025 Published: 2025-06-11 12:51:37... Pursuant to the Criminal Division's March 2023 Compensation Incentives and Clawbacks Pilot ... Program for Compensation Incentives and Clawbacks In March 2023, the Department launched ...
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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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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 ...