"[T]he issuer's annual determination of its Section 16 officers takes on an added importance.... This is an opportune time for an issuer to review its existing policy to determine if the provisions of the policy should be supplemented or amended in view of the SEC's proposed rules. For issuers without a clawback policy, the issuer should examine the necessity of such a policy.... [L]isted issuers should be aware that, the two largest proxy advisory firms, ISS and Glass Lewis, consider the presence of a clawback policy as a factor in making certain corporate governance recommendations."  MORE >>