"Although the timing for the new listing rules is uncertain, they could be effective within a year. Companies should consider taking the following actions: [1] Take a fresh look at their Section 16 officer group ... and develop additional record keeping procedures to track when Section 16 reporting status terminates. [2] Review existing clawback policies to consider what kinds of changes will be needed to conform to the new listing standards. [3] Review the current incentive compensation programs to identify various elements potentially subject to clawback as well as potential design changes. [4] Review the compensation committee charter to identify changes required for the committee's new responsibilities for overseeing enforcement of the clawback policy."  MORE >>