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JOBS Act Implementation Regulations
On March 3, the Criminal Division of the Department of Justice announced a two-part pilot program to encourage corporations to implement compliance programs with provisions for employee compensation incentives and clawbacks...more
DOJ’s decision to examine corporate compensation programs as an important part of a compliance program should be welcomed. DOJ’s initiative asks a very good question – how can incentives and disincentives be used to promote...more
The Justice Department did not just willy-nilly announce its embrace of clawbacks and deferred payment compensation punishment as a remediation tool for companies that suffer an enforcement action and settlement. To the...more
On 13 March 2014, the Prudential Regulation Authority (PRA), the U.K. regulator responsible for prudential supervision of banks, insurers and large broker-dealers, issued a consultation paper on bonus clawback (CP6/14). ...more