Clawback Provisions that Go Beyond SEC Requirements are Prevalent Among Large-Cap Companies
Harvard Corporate Governance
JULY 28, 2024
Posted by Stephen Hom, Erin Bass-Goldberg, and Emma van Beek, FW Cook, on Sunday, July 28, 2024 Editor's Note: Stephen Hom is a Principal, Erin Bass-Goldberg is a Managing Director, and Emma van Beek is a Consultant at FW Cook. This post is based on their FW Cook memorandum. In October 2022, the SEC adopted final clawback rules mandated by the Dodd-Frank Act, which required companies listed on the NYSE and Nasdaq to adopt a clawback policy to recover excess incentive compensation from current an
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