News & Analysis as of

Dodd-Frank Wall Street Reform and Consumer Protection Act Disclosure Requirements Proposed Regulation

The Dodd-Frank Wall Street Reform and Consumer Protection Act is a United States federal statute signed into law on July 21, 2010. The Act was passed in response to the Great Recession of the late 2000s and... more +
The Dodd-Frank Wall Street Reform and Consumer Protection Act is a United States federal statute signed into law on July 21, 2010. The Act was passed in response to the Great Recession of the late 2000s and includes broad reforms related to many aspects of the financial and banking industry. Notable sections of the Act include stricter regulations of the derivatives market, as well as the Volcker Rule, which restricts the trading practices of FDIC-insured institutions.    less -
Skadden, Arps, Slate, Meagher & Flom LLP

SEC Provides Update on Timing of Dodd-Frank Clawback Rules

Earlier this week, the U.S. Securities and Exchange Commission (SEC) updated the expected timeline for finalizing the New York Stock Exchange (NYSE) and Nasdaq listing standards requiring listed companies to adopt clawback...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Adopts Final Clawback Rules and Disclosure Requirements

On October 26, 2022, the U.S. Securities and Exchange Commission (SEC) adopted long-awaited final rules implementing the incentive-based compensation recovery (clawback) provisions of the Dodd-Frank Act. The final rules...more

White & Case LLP

SEC (Finally) Adopts Clawback Rules

White & Case LLP on

On October 26, 2022, the Securities and Exchange Commission ("SEC") adopted its long-awaited final rules on clawbacks. Under these rules, companies listed on the NYSE and Nasdaq will be required to adopt "clawback" policies –...more

Sullivan & Worcester

SEC Adopts Rules Requiring Compensation Clawback Policies

Sullivan & Worcester on

The SEC adopted long-pending rules requiring the recovery of erroneously awarded compensation as required by Congress in the Dodd-Frank Act. The rules will, among other things, require securities exchanges to adopt listing...more

Wilson Sonsini Goodrich & Rosati

Comment Periods Close Again for Proposed Clawback and Pay-for-Performance Rules: A Refresher

Two Securities and Exchange Commission (SEC) executive compensation rules on recoupment of incentive compensation in the event of a financial restatement (clawbacks) and the correlation between executive pay and company...more

Katten Muchin Rosenman LLP

SEC Comment Period Ends for Controversial Proposal Regarding Clawbacks of Executive Incentive Compensation Without Official Action

On October 14, Chairman Gensler announced that the Securities and Exchange Commission (SEC) would reopen the comment period for the controversial compensation clawback rule that it had initially proposed in 2015 in response...more

Goodwin

Financial Services Weekly Roundup: The Supreme Court Strikes Back On Single Director Leadership Structures

Goodwin on

In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more

Cooley LLP

Blog: What’s Happening With Those SEC Proposals For Dodd-Frank Clawbacks And Disclosure Of Pay For Performance And Hedging?...

Cooley LLP on

The SEC’s latest Regulatory Flexibility Agenda, which identifies those regs that the SEC intends to propose or adopt in the coming year— and those deferred for a later time—has now been posted. The Agenda shifts to the...more

Bracewell LLP

House Votes to Invalidate Extraction Payment Disclosure Rule

Bracewell LLP on

On February 1, 2017, the U.S. House of Representatives passed House Joint Resolution 41 to annul the Extraction Payment Disclosure Rule. The rule would require oil and gas companies to disclose in annual reports for fiscal...more

Winstead PC

Agencies Propose Incentive Compensation Rules for Financial Institutions

Winstead PC on

The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the U.S. Securities and Exchange Commission recently proposed new restrictions...more

Latham & Watkins LLP

Revised Rules on Dodd-Frank Incentive Compensation Requirements for Financial Institutions Proposed

Latham & Watkins LLP on

If adopted, the Proposed Rule would have a significant impact on compensation practices at covered institutions. On April 21, 2016, the National Credit Union Administration (the NCUA) issued a proposed rule regarding...more

Morrison & Foerster LLP

SEC Re-Proposes Rules for Resource Extraction Issuers Under Dodd-Frank Act

Morrison & Foerster LLP on

On December 11, 2015, the Securities and Exchange Commission (the “SEC”) proposed rules required under Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Section 1504 of the Act added...more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposes Rules for Resource Extraction Issuers Under Dodd-Frank Act

On December 11, 2015, the U.S. Securities and Exchange Commission (SEC) proposed new rules pursuant to Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”), which, if...more

Morrison & Foerster LLP

TLAC, and Then Some… A Preliminary Assessment of the Federal Reserve Board’s NPR

On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

FAQs on the SEC’s Proposed Clawback Rule

On July 1, 2015, the U.S. Securities and Exchange Commission (SEC) proposed a rule directing national securities exchanges and associations to establish listing standards that require public companies to adopt and enforce a...more

Latham & Watkins LLP

How to Navigate the SEC’s Proposed Mandate on Clawbacks

Latham & Watkins LLP on

US publicly listed companies should plan now for proposed stringent policies and required disclosures. Under the long-awaited proposed rules adopted by the Securities and Exchange Commission on July 1, 2015, generally,...more

Stoel Rives LLP

In Case You Missed It - Interesting Items for Corporate Counsel - July 2015

Stoel Rives LLP on

The SEC has finally proposed clawback rules, here, required by Section 954 of the Dodd-Frank Act. When adopted, the rules will require stock exchanges to propose and adopt listing standards that implement the requirements;...more

Benesch

SEC Proposes Rules Mandating Executive Compensation “Clawback” Policies

Benesch on

On July 1, 2015, the Securities and Exchange Commission (the SEC) proposed new rules that would mandate U.S. stock exchanges to establish and enforce standards requiring listed companies to adopt compensation recovery...more

Foley & Lardner LLP

SEC Proposes Rules on Compensation Clawback Policies

Foley & Lardner LLP on

On July 1, 2015, the Securities and Exchange Commission (SEC) proposed rules relating to compensation clawback policies. The rules, if adopted, would implement the requirements of Section 954 of the Dodd-Frank Wall Street...more

Eversheds Sutherland (US) LLP

SEC Proposes Controversial Rule Requiring Companies to Adopt No-Fault Clawback Policies

Recently, the U.S. Securities and Exchange Commission (SEC or the Commission) proposed a controversial new rule under the Dodd-Frank Act that instructs companies to establish policies that require “executive officers” to...more

Morgan Lewis

SEC Proposes Rules Requiring Companies to Adopt, Disclose, and Comply With Clawback Policies on Erroneously Awarded Executive...

Morgan Lewis on

On July 1, 2015, the US Securities and Exchange Commission (SEC) issued a long-awaited release (Proposing Release) proposing rules that would direct the national securities exchanges to establish listing standards requiring...more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposes New Compensation Clawback Rules

On July 1, 2015, the U.S. Securities and Exchange Commission (SEC) proposed new rules pursuant to Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which, if adopted, would require national...more

Fenwick & West LLP

Executive Compensation Alert: SEC Proposes “Clawback” Rules for Executive Compensation

Fenwick & West LLP on

On July 1, 2015, the Securities and Exchange Commission (the “SEC”) proposed rules directing the national securities exchanges (NYSE, NASDAQ, etc.) to create listing standards requiring listed companies to implement policies...more

Womble Bond Dickinson

SEC Proposes New Clawback Rules

Womble Bond Dickinson on

Last Wednesday, the Securities and Exchange Commission (SEC) proposed new Rule 10D-1 to require public companies to adopt and enforce clawback policies to recoup incentive-based compensation paid to current and former...more

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