On Oct. 26, 2022, the U.S. Securities and Exchange Commission released its final regulations implementing Dodd Frank Section 954 rules on the clawback of incentive compensation. Like the final regulations implementing SEC’s pay-for-performance rules (covered in an Aug. 30, 2022, McGuireWoods legal alert), the new clawback rules are extremely complicated, prescriptive in nature and will require significant analysis by public companies.
For assistance navigating these new rules, please see the linked slide deck and feel free to use the slides in internal presentations to management/business partners.
C-suite executives should be very interested in the incentive compensation clawback rules.
Please reach out to McGuireWoods’ employee benefits team with any questions about the rules or for a copy of the slides in PowerPoint format.