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What You Need to Know About the SEC's Final Clawback Rules
Orrick
[Guidance Overview] Nov. 3, 2022 "What are the new rules? ... What type of compensation is covered? ... What is a financial reporting measure? ... Which executives and what periods are covered? ... What must be recovered? ... How is it recovered? ... What types of restatements are covered? ... What must be disclosed? ... When to comply? ... How do the new rules compare to existing clawback requirements and proxy advisor guidance? [Side-by-side chart.] ... What should a compensation clawback policy look like? [Sample policy provided.]" |
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