On July 1, 2015, the Securities and Exchange Commission (SEC)
proposed rules relating to compensation clawback policies. The
rules, if adopted, would implement the requirements of Section 954
of the Dodd-Frank Wall Street Reform and Consumer Protection Act of
2010 (Dodd Frank) by directing national securities exchanges and
associations, such as the NYSE and Nasdaq, to adopt listing
standards that would require listed companies to develop and
implement compensation clawback policies.
Under the proposed rules, listed companies would be required to
have written compensation clawback policies that require the
recoupment of certain incentive-based compensation received by
current or former executive officers. The listing standards would
also require companies to make certain disclosures about their
clawback policies. The listing standards would generally apply to
all issuers with a class of securities listed on a national
securities exchange or association, including
