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Cancel Your Plans for the Independence Day Weekend So You Can Study the SEC's Proposed Compensation Clawback Rules!
Winston & Strawn LLP Link to more items from this source
[Guidance Overview]
July 1, 2015

"The proposal would require each company to adopt its recovery policy no later than 60 days following the date on which the listing exchange's listing rule becomes effective.... The proposed rules would apply to incentive-based compensation based on stock price or total shareholder return.... [T]he proposed rules would give companies the discretion not to recover excess incentive-based compensation received by executive officers if the expense of recovery would exceed the amount to be recovered ... However, the rules would require extensive disclosure of the circumstance of any decision not to pursue recovery."

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