The No-Fault Clawback

On October 26, 2022, the Securities and Exchange Commission adopted Rule 10D-1. It carries out Section 954 of the Dodd-Frank Act. Every listed company must have a policy to take back incentive pay, such as cash bonuses and stock awards tied to financial results, from its executive officers when it has to restate its financial results.

The rule reaches back three years and covers former executives as well as current ones. Fault does not matter. Recovery “is required regardless of whether the executive officer engaged in any misconduct.”

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