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Wells Fargo & Company Business Standards Report: Learning from... Published: 2019-02-13 11:51:12... The company also employs multiple clawback and forfeiture policies and provisions designed ... performance and forfeiture provisions, clawback policies, consideration of qualitative ...
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2025 proxy design Published: 2024-11-26 15:47:51... * Insider trading policy; no hedging or pledging Company securities * Compensation clawback policy * Majority voting standard for uncontested director elections - new in 2021 * ...
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23315936_2.DOC Published: 2011-06-14 19:13:05... Orderly Liquidation of Financial Companies, Including Executive Compensation Clawback Mark Ellenberg Jeff Robins Douglas Mintz +1 202 862 2238 +1 212 504 6554 +1 202 862 ...
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Microsoft Word - CopyOfFile_FIRM_DM-#13080949-v1-Alert_-_Global... Published: 2010-08-02 13:06:43... Clawback policies-Section 954 requires the SEC to revise its rules to direct the national ... of any security of an issuer that does not develop and implement a clawback policy. ...
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Webcast - "Pat McGurn's Forecast for 2015 Proxy Season" Published: 2025-06-24 15:03:54... And look out for what we call poor pay practices, such as the absence of broad clawback policies or nor having have pro rata vesting. That was the topic that scored its first ...
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PCAOB Developments Executive Summary Published: 2021-12-14 16:57:01... those addressing the Holding Foreign Companies Accountable Act (HFCAA), proxy voting advice, universal proxies, and recovery of erroneously awarded compensation ("clawbacks"). ...
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Board Composition Published: 2015-01-16 18:33:20... Equilar Contacts 2014 Board Composition & Recruiting Trends Report | 28 Related Content Links Clawbacks 101 Shareholder Value Transfer Analysis Behind The Numbers Say on Pay Videos ...
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New York Washington, D.C. Los Angeles Palo Alto... Published: 2014-06-30 02:29:01... that the company did not have a clawback policy or majority voting, and inaccurate statements of the CEO's compensation amount and the director voting results in the prior year). ...
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REUTERS/Erik de Castro Published: 2014-08-11 10:36:03... they prompt and effective?); business continuity arrangements in times of a disaster; clawback and recourse arrangements where service levels are not met; resourcing; and skill ...
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IPO Blueprint Capital Markets | Bass, Berry & Sims Published: 2017-08-15 20:10:04... This "clawback" provision has been used by the SEC to recover stock sale profits and ... Recovery of Erroneously Awarded Compensation ("Clawback") Policies. The Dodd-Frank Act ...
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Fifth Edition Contents Published: 2020-02-09 16:48:34... The scope of the "clawback" provision applies to any former or current officer for the three years prior to any restatement. Therefore, these incentive-based compensation ...
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Microsoft Word - Final-Client Alert - Dodd Frank Wall Street... Published: 2010-07-02 12:24:44... companies to gather Summary Compensation Table information for each employee). Clawbacks - The SEC is required to direct national securities exchanges to prohibit the listing ...
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IN THIS ISSUE SidleyPerspectives ON M&A AND CORPORATE GOVERNANCE Published: 2016-06-13 14:47:47... is believed to encourage inappropriate risks and would impose mandatory deferral and clawback provisions� It would also require such institutions to disclose certain information ...
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Guide to Effective Proxies ESG - HCM Published: 2019-09-05 12:24:54... elected for a one-year term expiring at the next Annual Meeting of Shareholders. * Clawbacks and Executive Risk Scorecard: We make all executive awards (cash and equity) subject ...
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Proxy Advisors and Market Power: A Review of Institutional Investor... Published: 2021-04-22 13:42:52... Adopt/Amend Remuneration Policy x Approve Clawback Provisions x Create Pay Disparity ... Adopt/Amend Supervisory Board Remuneration Policy x x Approve Clawback Provisions x x ...
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Public Engagement Report AUTOMATIC FOR THE PEOPLE Published: 2020-05-01 14:03:33... possible and no later than 2023. We contributed our views on improvements to malus and clawback provisions and discussed which ESG metrics the company may include in its schemes. ...
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BLUEPRINT FOR AN IPO TABLE OF CONTENTS Blueprint For An IPO 1 Published: 2016-09-07 18:59:25... This "clawback" provision has been used by the SEC to recover stock sale profits and ... Recovery of Erroneously Awarded Compensation ("Clawback") Policies. The Dodd-Frank Act ...
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Issues & Trends: AICPA National Conference on Current SEC and... Published: 2016-12-16 19:13:22... The OCA staff provided an example of an award with clawback features that would allow those with authority over compensation arrangements to apply broad discretion in determining ...
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Client Alert 2015 Year-End Securities ... Published: 2016-01-12 13:15:43... Without admitting or denying the allegations, the former co-head of equities trading agreed to pay a $125,000 civil penalty, and his subordinate agreed to both a clawback of ...
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Shareholder Voting Research & Analysis Published: 2024-10-30 09:23:09... 61 Recoupment Provisions (Clawbacks) ......Adopt or Amend Recoupment Provisions (Clawbacks) ......
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InsIDe Published: 2013-06-07 17:28:26... transactions, as well as rules mandating listing standards regarding compensation clawback policies. - The federal banking agencies proposed rules in early 2011 pertaining to ...
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Quick Guide to REIT IPOs Published: 2015-11-16 09:45:36... practices and related disclosure; * issuer adoption of a policy providing for a "clawback" of incentive compensation from current and former executive officers if it is ...
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DoDD-Frank ImplementatIon: Navigating the Road Ahead Published: 2012-12-20 16:56:13... transactions, as well as rules mandating listing standards regarding compensation clawback policies. - The federal banking agencies proposed rules in early 2011 pertaining to ...
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2181773-2024-GIC-ACDS-PDF Published: 2024-12-03 12:57:20... Executive clawback provisions based on more than just restatements (e.g., executive misconduct) No Yes Already adopted 38% 44% 18% 38% 45% 17% 36% 28% 36% 34% 32% 35% 26% 31% 43% ...
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Microsoft Word - LNDOCS01-#580306-v3-Government_Assistance_to... Published: 2008-11-13 14:58:52... The secured loans granted by the Bank of Italy under this provision are not subject to clawback under Italian insolvency rules. 3 Law Decree 155/2008 and Law Decree 157/2008 are ...
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Matters to Consider for the 2017 Annual Meeting and Reporting... Published: 2016-12-07 14:53:07... It is unclear when or whether these remaining mandates - hedging disclosures, pay-versus-performance and clawback provisions - will be finalized. In fact, in light of the upcoming ...
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New York Published: 2021-07-28 14:35:38... - Environmental 9 7 3 4 11% 14% 0 0 Clawbacks 3 2 3 2 34% 45% 0 1 Stock Retention 2 5 ... in 2019, each of which were related to clawbacks, which remains the compensation proposal ...
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Webcast - "The New World of IPOs: Dissecting the JOBS Act" Published: 2025-06-24 15:03:45... It is important to note that Section 11 liability still applies. Rule 10b-5 liability still applies. We're going to have new Dodd-Frank clawbacks when the SEC comes out with their ...
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Webcast: Challenges in Compliance and Corporate Governance (2020... Published: 2020-01-27 20:29:36... change and other environmental proposals - Senior executive compensation (including clawbacks and non-GAAP performance metrics) - Other governance matters, including written ...
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2024 Audit Quality Report Report Published: 2024-12-17 10:53:30... and climate-related disclosure rules and executive incentive compensation clawback rules; Provided additional guidance and training for audit teams regarding the ...
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Visio-Systemic.Oversight.BHC.vsd Published: 2010-07-09 09:35:57... (3) the ratio of the median employee annual total compensation to that of the CEO. Clawbacks - The SEC must, by rule, direct national securities exchanges and associations to ...
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GT Advisory_2025 Tax Act: Key Changes for Businesses and Individuals Published: 2025-07-18 12:51:22... The extension to file the amended income tax return matches the extended statute of limitations for the IRS to clawback a third quarter 2021 ERC refund. Accordingly, if the ...
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Capital Markets Guide 2012:Layout 1.qxd Published: 2012-03-26 20:41:11... however, as of January 15, 2012 many proposed rules have not been finalized, and still other rules, such as the executive compensation clawback rules, have not yet been proposed. ...
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Accounting Roundup Published: 2009-12-28 14:56:58... should account for cumulative unrealized gains (losses), carried interest, and clawback obligations in accordance with U.S. GAAP if the partnership agreement does not allow ...
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A Comparison of Silicon Valley Public Companies and Other Large... Published: 2016-12-06 19:04:44... Compensation: Governance: Policy Issues: General Business: § § Change-in-Control Payouts/Vesting/Golden Parachutes § § Clawbacks § § Death Benefits § § Director ...
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Georgeson Early Proxy 2024 Published: 2024-06-26 15:54:48... There were 81 proposals filed this year that related to executive and director severance and compensation (i.e. severance, clawbacks, binding vote on director compensation, ESG ...
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New York Published: 2022-08-08 16:27:17... - Social 12 13 4 8 10% 9% 0 0 Clawbacks 5 3 5 3 28% 34% 0 0 Compensation - ... Overall, the compensation proposals topics (e.g., golden parachutes, clawback policies and ...
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Audit Committee Update: 21 Financial Reporting Disclosure & Control... Published: 2021-02-03 13:11:08... auditor subject to a prohibition against retroactive application that may be designed to mitigate the risk of a Congressional clawback (under the Congressional Review Act of 1996). ...
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2023 Investment Stewardship Voting Spotlight Published: 2023-08-23 14:00:55... The company further introduced a clawback policy and eliminated discretionary awards from their compensation plans. As a result of these improvements, BIS supported Telefonica's ...
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PE Report Summer 2004.qxd Published: 2005-07-27 16:02:04... involve a contractual breach, such as the obligation to return distributed carried interest in the event of a fund-level clawback or indemnity. Contrast with legacy assets spinout. ...
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Investor Strategies for Incorporating ESG Considerations into... Published: 2015-05-28 12:49:11... For example, the Trust spearheaded a multi-stakeholder initiative in 2012 that sought to develop a sector-wide set of principles on executive compensation clawbacks for misconduct ...
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JS Published: 2013-02-14 16:13:00... The RSU awards are subject to a "clawback" provision described below. As described below, ... Oppenheimer, Sewell and Williams. Clawback ofRSU Awards. The named executive officers' RSU ...
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PAYCHECK PROTECTION PROGRAM WHERE ARE WE NOW? Published: 2020-08-06 17:49:54... Lender fees are subject to clawback within 1 year of disbursement of a PPP-loan if the SBA determines that a borrower was ineligible. * Agent Fee Limits: The CARES Act authorizes ...
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Sidley Austin provides this information as a service to clients... Published: 2017-11-29 18:27:01... * When a new employment contract is given to an executive that does not include a clawback provision and the company had a material restatement in the recent past, especially ...
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Name of Update Published: 2015-12-02 17:23:31... * When a new employment contract is given to an executive that does not include a clawback provision and the company had a material restatement in the recent past, especially ...
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Skadden, Arps, Slate, Meagher & Flom LLP Published: 2018-03-15 14:27:48... It is increasingly unclear when or whether these remaining mandates - hedging disclosures, pay-versus-performance and clawback provisions - will be finalized. In fact, perhaps ...
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TITLE I S S E S G C O M Published: 2022-02-15 15:14:44... C O M 6 0 o f 1 1 9 Does the company have a clawback or malus provision? (Q155) ▪ ... activities. ▪ For the US, ISS defines clawback as the company's ability to recoup ...
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S&C Publication: 2023 Proxy Season ReviewPart 1 Published: 2023-08-14 15:02:36... - Social 7 12 5 4 8% 10% 0 0 Compensation - Environmental 5 6 5 5 11% 10% 0 0 Clawbacks 3 5 2 5 42% 28% 0 0 Compensation - Other 63 7 12 3 8 19% 30% 0 0 1. 2.99x Severance ...
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WEF Paradigm - TRACKED as of 8.26 Published: 2016-11-28 18:11:00... This is undoubtedly a challenge, and institutions will need to develop customized approaches. Some institutions, for example, have implemented clawback arrangements or required ...
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Allstate Corporation Published: 2025-04-23 10:06:09... For example, a clawback feature was added to the Annual Executive Incentive Plan in 2009 ... strategies. ● Inclusion of a clawback feature in the Annual Executive ...