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Dodd-Frank Clawback Policy: Additional Action Required for NYSE-Listed Companies by December 31, 2023

Proskauer's Employee Benefits & Executive Compensa

NOVEMBER 30, 2023

The Securities and Exchange Commission adopted the final clawback rules under Dodd-Frank (the “ Final Rules ”) on October 26, 2022, and we discussed the detailed requirements of the Final Rules and related practical considerations in this earlier blog post. The Listing Manager can be accessed through this link.

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“Clawback Comeback”: DOJ’s New Focus on Clawbacks to Prevent Corporate Crime

Proskauer's Employee Benefits & Executive Compensa

OCTOBER 19, 2022

This new focus on “clawbacks” is intended to give general counsels and chief compliance officers the tools to implement “responsible corporate behavior” and to foster a corporate culture that both deters and punishes risky (and possibly criminal) behavior by top executives.

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Dodd-Frank Clawback Policy: Additional Action Required for NYSE-Listed Companies by December 31, 2023

“Clawback Comeback”: DOJ’s New Focus on Clawbacks to Prevent Corporate Crime

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