Topic
Clawbacks
154 published works
The SEC Institute Blog
SEC Extends Time to Approve Clawback Listing Standards But Rulemaking Process Remains Ahead of Original Schedule
Updated Clawback Policy template and adopting resolutions provided On April 24, 2023, the SEC extended to June 11, 2023 the period to approve, or begin the process to disapprove, the…
Public Chatter
Clawbacks: SEC (Slightly) Extends Deadline for It to Act on NYSE/Nasdaq Proposals
By Sue Morgan
On Monday, the SEC extended the deadline by which it must act on the proposed NYSE and Nasdaq listing standards that deal with “Recovery of Erroneously Awarded Executive Compensation.” The…
Known Trends
SEC Extends Time for Review of NYSE and Nasdaq Clawback-Related Listing Standards
On April 24, 2023, the U.S. Securities and Exchange Commission (SEC) extended the time period for its review and approval of the clawback-related listing standards from April 27, 2023 to…
Capital Markets
Updating Clawback Policies
By Rob Evans
The public comment period for the new NYSE and Nasdaq listing standards requiring public companies to have expanded clawback policies ended on April 3, 2023. The new standards will require…
The SEC Institute Blog
Clawback Rulemaking Process Moves Forward with Proposed Listing Standards
The SEC’s October 2022 Listing Standards for Recovery of Erroneously Awarded Compensation Final Rule requires national securities exchanges to propose and adopt requirements that listed companies have an appropriate “clawback…
Public Chatter
DOJ Announces Pilot Program and Updated Expectations on Corporate Compensation Programs
By Broc Romanek
The DOJ has been busy and clawbacks have been a hot topic for the Biden Administration in the wake of several high profile bank failures. The intersection of these two…
The Employer Report
Practical Considerations When Addressing New DOJ Compensation Incentives and Clawbacks Program
By Benjamin C. Ho, Sinead Kelly
Special thanks to Geoff Martin and Maria Piontkovska. On March 3, 2023, the Criminal Division of the United States Department of Justice ("DOJ") published details of a three year Pilot…
The CLS Blue Sky Blog
Davis Polk Discusses New DOJ Clawback, Messaging, and Monitorship Guidance
By Daniel S. Kahn, Greg D. Andres, Martine M. Beamon, Tatiana R. Martins, Fiona R. Moran
This month brought additional guidance from DOJ, this time the much-anticipated compliance guidance on compensation structures to incentivize compliance and the use of personal devices and messaging apps to engage…
Global Policy Watch
NYSE and Nasdaq Propose Clawback Listing Standards
By Kerry Burke, David H. Engvall, Matthew Franker, David Martin, Charlotte May, Brian Rosenzweig
On February 22, 2023, the New York Stock Exchange (“NYSE”) and the Nasdaq Stock Market (“Nasdaq”) filed rule proposals[1] to adopt new listing standards implementing Rule 10D-1 under the Securities Exchange…
Corporate and Securities Law
Stock Exchanges Publish Proposed Clawback Rules
Both the NYSE and Nasdaq have issued proposed clawback rules in connection with SEC Rule 10D-1. NYSE The NYSE proposes to comply with Rule 10D-1 by adopting proposed new Section…