February 25, 2016
Clawbacks: SEC Decides Not to Pursue Executives Who Reimbursed Company
– Broc Romanek, CompensationStandards.com
As noted in this Davis Polk memo, the SEC recently decided not to pursue two clawback actions under Section 304 because the individuals reimbursed the company for compensation they received after the company filed misleading financials…compare this to yesterday’s blog where the SEC instituted an action to recoup $11 grand…