Final SEC Clawback Rules: Key Dates That Issuers Need To Know

On November 28, 2022, the Securities and Exchange Commission (the "SEC") published the final clawback rules (the "Final Rules") under the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") in the Federal Register.

Now that the Final Rules have been published in the Federal Register, issuers should be aware of the following key deadlines¹:

• January 27, 2023: The Final Rules become formally effective (60 days after the Final Rules were published in the Federal Register).
• February 24, 2023: Outside date for national securities exchanges ("exchanges") to file proposed listing standards that comply with the Final Rules (this is the last business day before the 90^th day post-publication window closes on February 26, 2023).