"On October 14, 2021, the [SEC] issued a release reopening the comment period for the clawback rules initially proposed on July 14, 2015 to implement the provisions of Section 954 of the Dodd-Frank Act.... While the SEC's release was styled largely as questions for the investment community and their advisors to consider, the tenor of the questions suggests that the SEC is gearing up to offer an expansive view of clawback rules, with particular focus on the types of restatements that trigger applicability of the rules."