The Pay & Proxy Podcast: FAQs on Implementing Dodd-Frank Clawback Policies (11/23)
- "Little r" restatements & the SEC's expansive interpretation of what constitutes "material noncompliance with any financial reporting requirement"
- Steps a company needs to take under a clawback policy following a determination that a restatement is required
- "Difficult" financial metrics where the erroneously awarded compensation can't be determined by a simple mathematical recalculation
- Challenges with collecting erroneously awarded compensation
- Planning ahead for policy implementation
- When erroneously earned shares have been sold at a gain
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