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| Highlights of the SEC's Proposed Clawback Rule Ogletree Deakins  [Guidance Overview] Sept. 15, 2015 "Which companies are affected? ... Who is an executive officer? ... What triggers a clawback? ... What time period of compensation is subject to recovery? ... How much incentive-based compensation is subject to recovery? ... Which types of compensation are not subject to recovery? ... What is the consequence of non-compliance? ... When would companies have to comply? ... What is the practical impact at this stage?" |
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