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Results from: TheCorporateCounsel.net
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DISK124:[20ZCZ1.20ZCZ43501]BC43501A.;3 Published: 2025-02-25 17:20:54... Stock Robust Code of and Compensation Clawback Ownership Guidelines Conduct/Ethics ... resort to the pledged securities. * Clawback Policy: The Board has the authority to ...
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Nasdaq Guidance Published: 2025-06-02 00:00:00... NYSE/Nasdaq '23 Proposal "Letter from 39 Law Firms on Clawback Listing Standards" (4/23) Greenberg Traurig (3/23) BakerHostetler (3/23) Compensation Advisory Partners (3/23) ...
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http://www.bracewellgiuliani.com/index.cfm/fa/news.advisory_pri Published: 2008-10-16 21:54:26... and excessive risks that threaten the value of the participating institution; require clawback of any bonus or incentive compensation paid to a senior executive based on statement ...
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The_Outlook_for_Financial_Regulatory_Reform_Under_President_Trump Published: 2016-12-01 16:08:09... What would be the impact on executive compensation rules and disclosure requirements? Clawbacks of incentive compensation under Section 10D of the Exchange Act (mandated by the ...
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#16-3341 Compendium InDesign Template R1.indd Published: 2016-12-12 19:39:10... The rules that have not yet been finalized, which include the requirement for mandatory clawbacks of executive bonuses and disclosure of the extent to which companies have ...
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Finding the S in ESG: Boardroom and Employee Considerations Published: 2020-10-29 17:48:13... and "clawback") for inappropriate behaviours and risk-taking is a powerful tool in the regulation of culture and practices within firms. The use of malus and clawback has also ...
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WORK Updated Published: 2018-07-10 17:46:08... issues of executive pay have sought clawbacks - the recovery of executive pay as an ... often submit shareholder proposals requesting their companies to adopt clawback policies. ...
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A LOOK AHEAD TO THE 2012 PROXY SEASON By Shirley Westcott March... Published: 2012-03-12 13:03:04... The two banks, along with Morgan Stanley, were also prodded by the New York City pension funds to strengthen their clawback policies to hold senior executives financially ...
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Tweet Aon Worldwide Published: 2017-11-20 14:14:49... by Topic Corporate Governance (15) Executive Compensation (7) ISS (4) Pay Ratio (2) Clawback (1) see all Consulting | Products | Services | Contact Us | Careers Copyright © 2017 ...
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Mellon Proxy Guidelines Summary Published: 2024-10-29 14:27:46... F. Clawbacks When determining the effectiveness of a company's Clawback/recoupment policy, the Committee will consider: (1) the amount of information the company provides in its ...
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DocName Published: 2010-03-12 23:20:58... and director stock ownership guidelines and director stock ownership; * Disclosure of clawback provisions; * NEO multi-year guaranteed bonuses or tax gross-ups on perks other than ...
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Section 5.1 Core Objectives of Executive Pay Published: 2019-09-18 13:43:50... Other boards may consider such restrictions unnecessary to the extent that awards include extended vesting periods. Section 5.7 Compensation Recovery Clawback policies should ...
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Cooley Ale Published: 2008-12-04 16:06:12... 2008. For example, historically RMG would not support a shareholder proposal on the "clawback" of certain incentive pay if the company had instituted a correspond- ing policy; ...
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http://www.dlapiper.com/senator-dodd-introduces-revised-financi Published: 2010-03-19 18:45:32... This provision is similar to the House-passed bill and the original Dodd November draft. However, the new Dodd proposal goes further by requiring a clawback to recover any ...
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View PDF Published: 2024-12-19 14:54:37... policies implemented by the Biden DOJ, like the DOJ Corporate Whistleblower Awards Pilot Program (see our client update) and the DOJ Clawback Pilot Program (see our client update). ...
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A Comparison of Silicon Valley 150 Companies Published: 2018-10-15 12:32:59... 0 0 1 0 0 1 0 0 0 0 0 0 0 0 1 0 0 0 2 2 Clawbacks 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 2 5 ... 0 0 0 0 28.1 0 0 27.9 0 0 25.9 0 0 23.9 Clawbacks 1 0 0 0 0 0 37.9 0 0 36.6 0 0 29.2 0 0 ...
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Silicon Valley A Comparison of Silicon Valley Companies and Published: 2019-11-21 14:39:44... 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 2 2 Clawbacks 0 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 2 2 ... 6.0 20.2 13.1 4.9 16.3 9.0 4.2 14.5 7.8 Clawbacks 0 1 0 0 0 0 0.0 37.9 0.0 0.0 36.6 0.0 ...
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ANNUAL CORPORATE GOVERNANCE REVIEW Published: 2012-01-17 19:25:21... golden parachutes (a popular resolution over the past decade and three resolutions voted on in 2010), and (iii) mandatory clawback provisions (three resolutions voted on in 2010). ...
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2017 Mid-Year Securities Enforcement Update Published: 2017-07-20 16:47:26... question and thus the SEC did not seek a clawback. 7 Also in January, the SEC instituted ... the company for bonuses and stock awards and thus no clawback proceedings were necessary. ...
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<<Brochure Title>> Published: 2017-02-16 17:59:39... Equity Clawback Option As a potentially important exemption from the general rule that the ... upon not less than 30 nor more than 60 days' notice (so-called "Equity Clawback Option"). ...
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PUBLICATIONS New Landmark Foreign Extortion Prevention Act Targets... Published: 2024-02-06 10:22:06... Harbor Policy; DOJ Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance Regarding Electronic Communications, and Resource ...
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Governance Group, Published: 2010-07-22 19:36:37... new "say on pay" rules) "or any other signifcant matter, as determined by" the SEC. Clawback of Incentive-Based Executive Compensation The Act also expands upon Section 304 of ...
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ATTORNEY ADVERTISING Published: 2010-07-22 13:48:36... under Item 402 of Regulation S-K as in effect on July 20, 2010. * Clawbacks The scope of the clawback provisions contained in Sarbanes-Oxley has been expanded by the ...
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Sidley Best Practices Calendar for Corporate Boards Published: 2022-08-09 13:13:34... meeting * Review policies relating to clawback of executive compensation or consider ... program policies and procedures - Clawback policy - Hedging policy - Stock ...
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SIDLEY UPDATE Paycheck Protection Program Update - SBA Issues... Published: 2020-05-26 16:29:10... Lender processing fees are subject to clawback if the SBA determines a borrower was ineligible for a PPP loan within one year after the loan was disbursed. Regardless of whether a ...
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SIDLEY UPDATE Making Sense of U.S. DOJ's New Monaco Memo on Corporate... Published: 2022-09-22 15:55:28... reward" positive compliance actions) and penalties for employees whose actions contributed to criminal conduct (such as clawback provisions or partial escrowing of compensation). ...
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Proxy Voting Fact Sheet Published: 2014-03-31 15:43:00... Topic Voted proposals As a percentage of votes cast As a percentage of votes outstanding For Against Abstain For Against Abstain Non Votes Recoup incentive pay ("clawback") 1 36.4% ...
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Update: SBA Clarifies PPP Loan Forgiveness Requirements and Loan... Published: 2020-05-26 14:16:51... Furthermore, lenders would be subject to a processing fee clawback if they fail to otherwise fulfill their obligations for document collection and retention, as described in the ...
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Attorney Advertising CORPORATE Published: 2017-05-05 13:46:07... corporate employees and directors); and clawbacks (requiring disgorgement of incentive ... disclosure of hedging activities, clawbacks of executive compensation, and the ...
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WSGR Alert Published: 2023-09-28 18:07:46... share repurchases, insider trading plans, and executive compensation (specifically, "pay versus performance" disclosure and the required adoption of clawback policies). ...
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Microsoft Word - 4-29-05-Summary of FASB Statement No. 123-R... Published: 2005-04-29 15:27:12... Clawback Provisions - Contingent features such as "clawback provisions" that may cause the recapture of equity compensation profits are not considered when estimating grant-date ...
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Management Alert Published: 2011-08-04 12:27:27... officers to other employees (Section 953 of the Dodd-Frank Act), expanded executive clawbacks in the event of a restatement (Section 954 of the Dodd-Frank Act) and policies ...
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The New RiskMetrics Group Brand Published: 2008-01-20 19:55:54... C l a w b a c k L i n k P a y t o P e r f o r m S E R P S Backdaters draw scrutiny Hot topics: Clawbacks, consultant conflicts and SERPS Source: ISS Governance Services Pay for ...
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Securities and Capital Markets Published: 2014-11-11 15:26:16... in this area included clawback provisions, the imposition of policies that executives hold shares until retirement, and limitations on the accelerated vesting of equity awards. ...
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A Comparison of Silicon Valley 150 Companies Published: 2017-11-02 19:05:50... 0 1 0 0 1 0 0 0 0 0 0 0 0 1 0 0 0 0 2 Clawbacks 0 0 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 5 ... 0 0 0 28.1 0 0 27.9 0 0 25.9 0 0 23.9 0 Clawbacks 0 0 1 0 0 0 0 0 45.1 0 0 44.7 0 0 39.1 0 ...
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SHAREHOLDER PROPOSAL DEVELOPMENTS DURING THE 2022 PROXY SEASON Published: 2022-07-13 10:25:08... Executive compensation proposals include proposals addressing: (i) performance metrics, including the incorporation of sustainability-related goals; (ii) compensation clawback ...
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New York Washington, D.C. Los Angeles Palo Alto... Published: 2014-11-08 15:38:40... to peers, vesting requirements in last three years of CEO equity grants, equity clawback policy, plan duration, share-holding requirements and performance grant ratio of ...
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W&C Standard Template Published: 2018-01-18 17:19:07... Compensation Clawbacks 64 In 2015, the SEC proposed rules that would require any company ... also specifies disclosure requirements relating to clawback policies and actual clawbacks. ...
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STRAIGHT TALK IS GOOD BUSINESS. Published: 2014-07-10 11:24:51... the executive compensation clawback mandate of Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the clawback of executive compensation from ...
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Financial CHOICE Act 2.0 Passes House Financial Services Committee Published: 2017-05-09 16:43:31... "say when on pay" vote. Would limit clawbacks of compensation to those current or ... would require mandatory deferrals and clawback Would repeal and modify many key ...
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Emergency Economic Published: 2008-10-16 19:40:22... These restrictions require qualifying financial institutions to: » ensure that senior executive compensation does not encourage excessive risk taking; » impose a clawback on ...
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New FTC Rulemaking Seeks to Ban Most Non-Competes Published: 2023-01-10 12:29:51... Foreign Subsidy Disclosure Requirements to HSR Rules How to Navigate the SEC's New Clawback Rules New FTC Policy Statement Expands Scope of "Unfair" Methods of Competition SEC ...
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Microsoft Word - CPP PRIVATE FINAL.DOC Published: 2008-12-02 15:30:36... Compensation Restrictions Participating QFIs must: * ensure that compensation does not encourage excessive risk taking; * impose a clawback on compensation paid based on financial ...
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Los Angeles | Century City | New York | San Francisco | Silicon... Published: 2008-11-22 18:50:47... Compensation Restrictions Participating QFIs must: * ensure that compensation does not encourage excessive risk taking; * impose a clawback on compensation paid based on financial ...
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Shareholder Activism and the "Eclipse of the Public Corporation... Published: 2008-10-09 17:01:22... Unless directors are particularly careful with re- spect to severance, perks, the relation of pay to performance, and reasonable clawback arrange- ments to provide for recoupment ...
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printmgr file Published: 2013-06-28 19:09:00... our pay for performance philosophy. * Clawback - In September 2010, our Board adopted a ... The clawback pertains to any excess income derived by the executive officer based on ...
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FOR PROXY CIRCULAR DISCLOSURE 3304-20 Queen St, Toronto, ON,... Published: 2021-01-20 18:40:52... Pembina Pipeline Corporation, 2020 Proxy Circular, page 51 Clawback policy We recognize the importance of clawback provisions in promoting ethical conduct and strong ...
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Arbitration Provisions in Corporate Governance Documents Published: 2012-04-27 16:18:00... The new sections direct the Commission to direct the SROs to adopt listing standards relating to compensation committees that meet detailed standards and to compensation "clawbacks...
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C O R P O R A T E G O V E R N A N C E Published: 2011-03-21 17:14:22... Clawbacks-Section 954 of the Act also creates a new Section 10D of the Exchange Act ... require misconduct by the company or any offcer as a condition to invoking the clawback. ...
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Via Electronic Mail: Rule-Comments@sec.gov Published: 2020-08-11 15:52:45... receiving more than 40 percent. 5 Proposals for company policies on executive- pay clawbacks often received limited voting support in early years (e.g., averaging 10.7 percent in ...