News & Analysis as of

Rule 10D-1 Proposed Regulation

Keating Muething & Klekamp PLL

SEC Extends Period to Act on Exchange Clawback Rules

On April 24, 2023, the Securities and Exchange Commission extended the time period to take action on proposed listing standards to implement the Dodd-Frank “Clawback Rules.” As discussed in a previous blog post, the SEC...more

Goodwin

SEC Proposes Mandatory Incentive Compensation Clawback Rules

Goodwin on

On July 1, 2015, the Securities and Exchange Commission proposed rules, consisting of new Rule 10D-­1 and related rule and form amendments, that would require clawbacks of incentive compensation received by executive officers...more

Allen Matkins

The SEC’s Unconvincing Case Against Indemnification

Allen Matkins on

The Securities and Exchange Commission’s proposed rules take a hard line against issuers indemnifying executives against clawbacks: We believe that indemnification arrangements may not be used to avoid or nullify the recovery...more

Katten Muchin Rosenman LLP

SEC Proposes Rule Requiring Executive Compensation Clawbacks

On July 1, the Securities and Exchange Commission proposed for public comment a new rule and rule amendments to implement provisions of Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. In...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

Allen Matkins

What The SEC Pretermitted In Proposing Clawback Policy Rule

Allen Matkins on

The Securities and Exchange Commission began the month by issuing proposed rules that would direct national securities exchanges and associations to establish listing standards requiring companies to adopt policies that...more

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