Securities
Jan. 27, 2025
Compensation clawbacks: The initial disclosures
The implementation of Section 10D clawback rules has begun to reshape executive compensation policies, as companies navigate disclosure requirements, recovery analyses, and the broader implications for risk management and governance.
Mark A. Borges
Principal
Compensia, Inc.
The impact of Section 10D of the Securities Exchange Act of 1934 has been a long time coming. Originally added to the federal securities laws in 2011 by Section 954 of the Dodd-Frank Act of 2010, it took the SEC until 2015 to propose - and until 2022 to adopt - final rules implementing the provision. Even then, it took another seven months for the national securities exchanges to receive SEC approval of new listing standards prescribing exactly how the compensation rec...
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$795 for an entire year!
Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)
Already a subscriber?
Sign In