7 pages. "Registrants should immediately consider amending their incentive compensation plans so that the new recovery rules are applicable.... [To] take an extreme case, if the SEC finalizes its rule in 2015 and the rule is effective upon finalization, a calendar year registrant must be able to recover IBC in the event the 12/31/15 financials are restated and the restatement affects currently outstanding IBC awards, including long-term incentives granted in prior years in which payment is affected by results in 2015. This contractual right of recovery will be particularly important with respect to executive officers who are no longer employed by the registrant -- absent a rule requiring repayment, the registrant may be unable to collect, which could lead to delisting."  MORE >>