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A Plain English Guide to the Compensation Clawback Rules
OrrickLink to more items from this source
[Guidance Overview]
July 23, 2015

"As accounting restatements occur relatively infrequently, and the severity is often modest, the proposed 'clawback' rules represent more of a 'check the box' compliance activity than a real enforcement threat. [Here is a brief summary of the rules:] When to comply? ... What compensation is covered? ... What executives are covered? ... What must be recovered? ... How is it recovered? ... When is a restatement required?"

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