The Advisors' Blog

This blog features wisdom from respected compensation consultants and lawyers

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…