Topic
Clawbacks
154 published works
The CLS Blue Sky Blog
Davis Polk Discusses NYSE and Nasdaq Clawback Rule Proposal
By Kyoko Takahashi Lin, Ning Chiu
On February 22, 2023, the New York Stock Exchange and the Nasdaq Stock Market released their respective versions of a proposed rule that implements the SEC’s clawback rule mandated by Section 954 of the Dodd-Frank Act.…
The SEC Institute Blog
Disclosures and Form Changes for the “Recovery of Erroneously Awarded Compensation” a/k/a “Clawback” Rules
As we discussed in this earlier post, the SEC’s October 2022 “Listing Standards for Recovery of Erroneously Awarded Compensation” rules will require companies whose securities are listed on national securities…
Free Writings + Perspectives
NYSE and Nasdaq Propose Clawback Listing Standards
The US Securities and Exchange Commission (SEC) adopted Rule 10D-1 in October 2022, directing national securities exchanges to establish listing standards that prohibit the listing of any security of a…
Known Trends
NYSE and Nasdaq Propose Clawback-Related Listing Standards
On February 22, 2023, the New York Stock Exchange (NYSE) and Nasdaq filed proposed rule changes with the U.S. Securities and Exchange Commission (SEC) to adopt listing standards related to…
The SEC Institute Blog
The SEC’s “Recovery of Erroneously Awarded Compensation” a/k/a “Clawback” Rules – A Policy Template and Timing and Implementation Details
The SEC’s October 2022 “Listing Standards for Recovery of Erroneously Awarded Compensation” Final Rulewill require companies whose securities are listed on national securities exchanges to develop and adopt policies for…
Capital Markets
Annual SEC Reporting – Two Points to Note
By Rob Evans
Public companies with a calendar fiscal year are already in the process of preparing their Annual Report on Form 10-K and their glossy Annual Report to Shareholders. Here are two…
Public Chatter
Corp Fin Issues “Form 10-K Checkbox” Guidance
Last Friday, Corp Fin issued four new Exchange Act CDI 121H.01-04 to provide some guidance relating to the new clawback rules that the SEC adopted in October. The first of…
Known Trends
Corp Fin Publishes New CDIs on Clawback Rules – Addresses Cover Page Check Boxes
On January 27, 2023, the SEC’s Division of Corporation Finance (Corp Fin) published four new Compliance and Disclosure Interpretations (CDIs) relating to the SEC’s recently adopted clawback rules. Please refer…
Nonprofit Law Prof Blog
Nonprofits Worry About FTX Charitable Donation Clawbacks
Saturday's WSJ had an interesting story about FTX's continuing efforts to recover SBF's (pictured above) charitable contributions to some pretty heavy hitter nonprofits before FTX imploded. Organizations like Stanford University…
Credit Chronometer
New Regulations, New Bankruptcy Law will be FTX’s Legacy
As we learn more about FTX’s operations, speculation is slowly giving way to certainty. It’s clear FTX’s collapse will have a deep impact on the future of regulations, its bankruptcy…