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Final SEC Clawback Rules: Key Dates that Issuers Need to Know

Proskauer's Employee Benefits & Executive Compensa

On November 28, 2022, the Securities and Exchange Commission (the “SEC”) published the final clawback rules (the “Final Rules”) under the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) in the Federal Register.

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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

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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Deadlines for the Adoption of Clawback Policies Extended

McDermott Will & Emery Employee Benefits

The US Securities and Exchange Commission (SEC) recently approved amendments to clawback policy listing standards proposed by the New York Stock Exchange (NYSE) and the Nasdaq Stock Market LLC (Nasdaq) that extend the effective date of the exchanges’ respective listing standards to October 2, 2023.

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SEC Adopts Final Pay Versus Performance Rules

McDermott Will & Emery Employee Benefits

On August 25, 2022, the US Securities and Exchange Commission (SEC) adopted final rules to implement the pay versus performance disclosure requirement mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The post SEC Adopts Final Pay Versus Performance Rules appeared first on EMPLOYEE BENEFITS BLOG.

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New SEC Rules Heighten Scrutiny Over Executive Pay

McDermott Will & Emery Employee Benefits

On August 25, 2022, the US Securities and Exchange Commission (SEC) adopted final rules imposing new mandatory “pay for performance” disclosures for most public companies (foreign private issuers, emerging growth companies and registered investment companies are excluded).

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Addressing DOJ’s New Compliance Focus on Executive Compensation

McDermott Will & Emery Employee Benefits

The new compliance focus on executive compensation, as announced by the US Department of Justice (DOJ) on March 3, 2023, has significant implications for how healthcare organizations address both corporate compliance and compensation programs for their executives.

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

Proskauer's Employee Benefits & Executive Compensa

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.