SEC Revisits Proposed Rule on Recovery of Erroneously Awarded Exec Compensation  

September 12, 2022

Kathy Jaffari and Rikisha Collins discuss the clawback rule proposed in July 2015 to strengthen the disclosures and standards for recovery of erroneously awarded compensation by publicly listed companies in The Legal Intelligencer.

Kathy and Rikisha explain the memorandum issued by SEC’s Division of Economic and Risk Analysis (DERA) regarding “supplemental data and analysis of the adoption of the compensation recovery provisions” and provide a brief analysis of the proposed rule. 

“As the SEC continues to prioritize recovery of erroneously awarded executive compensation in rulemaking and enforcement, we encourage public companies to monitor the development of the final rule and additional guidance on executive compensation policies and disclosures,” they stated. 

To read the full article, click here.

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Rikisha Collins


(215) 366-4464

Katayun Jaffari

Chair, Corporate Governance
Co-Chair, Capital Markets & Securities
Chair, ESG

(215) 665-4622

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